1. Prerequisites for Cross-Border E-Commerce Customs Declaration
1.1 Why is a Specialized Cross-Border E-Commerce Customs Declaration Mode Necessary?
The traditional general trade customs declaration mode (0110) is designed for trade characterized by "large volumes, high values, and individual shipment declarations." Cross-border e-commerce has completely different characteristics:
| Trade Characteristic | General Trade | Cross-Border E-Commerce |
|---|---|---|
| Value per Shipment | Thousands to tens of thousands of yuan | Tens to thousands of yuan |
| Items per Shipment | Large quantities | 1-10 items |
| Number of Buyers | Few B2B clients | Thousands to millions of C-end consumers |
| Order Frequency | Low frequency (a few shipments per month) | High frequency (thousands of orders daily) |
| Declaration Method | Complete individual declaration | Requires aggregated/simplified declaration |
Using general trade declaration for cross-border e-commerce results in: Declaration cost > Value of goods → Economically unfeasible.
Therefore, since 2014, the General Administration of Customs has successively introduced four supervision codes specifically designed for e-commerce scenarios.
1.2 Overview of the Four Modes
┌─────────────────────────────┐
│ Cross-Border E-Commerce Customs Supervision Modes │
├──────────────────┬──────────────────┤
│ Export │ Import │
├──────────────────┼──────────────────┤
│ 9610 │ 1210 (Bonded Import) │
│ 9710 │ │
│ 9810 │ │
└──────────────────┴──────────────────┘
| Code | Full Name | Direction | Applicable Scenario |
|---|---|---|---|
| 9610 | Cross-Border E-Commerce Retail Export | Export | B2C, direct purchases by consumers (small parcel direct delivery) |
| 9710 | Cross-Border E-Commerce B2B Direct Export | Export | B2B, transactions between cross-border e-commerce enterprises |
| 9810 | Cross-Border E-Commerce Export Overseas Warehouse | Export | Overseas warehouse/FBA stocking export |
| 1210 | Cross-Border E-Commerce Bonded Retail Import | Import | Delivery from bonded warehouse to domestic consumers |
2. 9610: Cross-Border E-Commerce Retail Export
2.1 Definition and Applicable Scenarios
9610 (Cross-Border E-Commerce Retail Direct Purchase Export) is applicable to models where cross-border e-commerce enterprises retail goods to overseas consumers through e-commerce platforms and logistics enterprises deliver them directly via small parcels.
Typical Scenarios: - Amazon sellers using international small parcels to ship directly to overseas individual buyers - Direct mail orders on platforms like AliExpress/Wish/Shopee - DTC (Direct-to-Consumer) model's international small parcels on independent websites
2.2 Declaration Process
Order created → Triple data matching (Order/Payment/Logistics) → Manifest verification → Consolidated declaration → Release and shipment
| Step | Description |
|---|---|
| Triple Data Matching | Real-time matching of three orders: E-commerce platform (order info) + Payment enterprise (payment info) + Logistics enterprise (logistics info) |
| Manifest Verification | Declaration manifests from the cross-border e-commerce enterprise (simplified declaration, not full customs declarations) |
| Consolidated Declaration | Manifests for the same enterprise, same conveyance, and same port of entry/exit can be consolidated into one declaration every 7 days/monthly (facilitating tax refunds and forex collection) |
| Release and Shipment | Quick release after verification, generally 1-4 hours |
2.3 Core Advantages of 9610
| Advantage | Description |
|---|---|
| Low barrier | No need for full declaration on each shipment; small parcels are also compliant |
| Tax refund available | Export tax refunds can be applied for after aggregated declaration (requires legal purchase invoices) |
| Foreign exchange settlement available | Normal foreign exchange collection via cross-border payment institutions |
| Fast clearance | Automated system matching ensures high clearance efficiency |
| Compliance assurance | Three-document matching avoids risks of fake orders and data fraud |
2.4 9610 vs. Postal / Courier Small Parcels
Many cross-border e-commerce sellers initially use postal small parcels or courier companies for direct shipping without 9610 declaration. Comparison:
| Comparison Dimension | 9610 Declaration | Postal/Courier Direct Shipping |
|---|---|---|
| Legal status | Formal declaration, with customs statistics | Informal clearance, no trade statistics |
| Export tax refund | ✅ Available | ❌ Not available |
| Foreign exchange settlement | ✅ Available | ❌ Cannot enter trade foreign exchange receipts |
| Compliance risk | Compliant | Risk of non-compliant declaration |
| Speed | Customs clearance 1-4 hours | Depends on destination country's customs |
| Applicable platforms | All platforms | No restrictions, but bears compliance risk |
III. 9710: Cross-Border E-Commerce B2B Direct Export
3.1 Definition and Applicable Scenarios
9710 (Cross-Border E-Commerce B2B Direct Export) applies to the model where e-commerce enterprises, after concluding transactions with overseas enterprises through e-commerce platforms, export directly to those overseas enterprises. It was piloted in some customs offices from July 2020 and was fully rolled out in 2021.
Typical Scenarios: - B2B order exports from Alibaba International Station - Order exports after transactions concluded on Made-in-China.com - Order-by-order exports to overseas small B buyers through platforms
3.2 Comparison with General Trade (0110)
| Comparison Dimension | 9710 | 0110 |
|---|---|---|
| Transaction method | E-commerce platform (online conclusion) | Traditional offline contract signing |
| Document requirements | Electronic order replaces paper contract | Requires paper contract |
| Declaration method | Supports simplified declaration | Full declaration |
| Tax refund | ✅ Available | ✅ Available |
| Foreign exchange settlement | ✅ Available | ✅ Available |
| Applicable enterprises | Foreign trade enterprises on e-commerce platforms | All enterprises with import/export operation rights |
3.3 Declaration Process
E-Commerce Platform Order → Data Exchange with Customs → 9710 Declaration → Document Review/Inspection → Release → Shipment → Customs Clearance
Key Declaration Points: - Declare through the "Single Window" cross-border e-commerce module - Order information is automatically pushed by the e-commerce platform or manually entered by the enterprise - Aggregated declaration is supported (same enterprise, same transport mode, same destination country)
IV. 9810: Cross-Border E-Commerce Export via Overseas Warehouse
4.1 Definition and Applicable Scenarios
9810 (Cross-Border E-Commerce Export via Overseas Warehouse) applies to the model where e-commerce enterprises first export goods to overseas warehouses (including Amazon FBA warehouses and third-party overseas warehouses), and then the overseas warehouses deliver the goods to consumers based on orders.
Typical Scenarios: - Amazon FBA first-leg shipments - Third-party overseas warehouse stocking (e.g., Goodcang, Winit, 4PX, etc.) - Self-built overseas warehouse replenishment
4.2 Specifics of 9810
9810 is similar to general trade (0110) in operation — both require normal customs declaration procedures for export — but the core difference lies in the timing:
0110: Sales contract signed → Customs declaration export → Foreign exchange settlement/tax refund (concurrent)
9810: Customs declaration export → Goods arrive at overseas warehouse → End sales → Foreign exchange settlement/tax refund after sales confirmation (spanning months)
| Dimension | 0110 | 9810 |
|---|---|---|
| Is there a buyer at the time of export? | ✅ Yes, a confirmed overseas buyer | ❌ End buyer not yet determined |
| Is ownership transferred at export? | ✅ Transferred | ❌ Not yet transferred |
| Tax refund timing | Tax refund declared immediately after export | Must be confirmed after final sale is completed |
| Foreign exchange settlement timing | Foreign exchange received immediately after export | Foreign exchange received after final sale |
4.3 Key Declaration Points
For 9810 declarations, the remarks column of the customs declaration form must indicate "Overseas Warehouse Model" and include the following information:
- Storage address of the exported goods in the overseas warehouse
- E-commerce platform name and store information
- FBA tracking number (if applicable)
Note: The tax refund declaration for 9810 differs from general trade — it is not refunded immediately upon export. Instead, the tax refund can only be processed after the goods are sold through the overseas warehouse, supported by final sales records. This is something cross-border e-commerce sellers must be fully aware of.
V. 1210: Cross-Border E-Commerce Bonded Retail Import
5.1 Definition and Applicable Scenarios
1210 (Cross-Border E-Commerce Bonded Retail Import) applies to the import model where e-commerce enterprises deposit overseas goods on a bonded basis into special customs supervision areas (bonded warehouses). After consumers place orders, the goods are shipped from the bonded warehouse in the form of personal parcels.
Typical Scenarios: - Bonded warehouse delivery orders from Tmall Global, JD Worldwide, Kaola Haigou - Cross-border e-commerce import businesses within comprehensive bonded zones
5.2 Core Advantages
| Advantage | Description |
|---|---|
| Bonded stocking | Goods are stored in bonded status; no tax is paid before sale |
| Fast delivery | Shipped from domestic bonded warehouses, delivery in 1-3 days (vs. 7-15 days for direct mail) |
| Duty-free within personal quota | Within the annual transaction limit (currently RMB 26,000/year), customs duty is 0%, and consumption tax and VAT are at 70% of the standard rate |
| Easy returns | Consumer returns can be sent back to the bonded warehouse, reducing losses |
5.3 1210 vs. CC (Postal Parcel) Comparison
| Comparison Dimension | 1210 | CC (Personal Parcel Postal) |
|---|---|---|
| Applicable platforms | Cross-border e-commerce platforms | No restrictions |
| Quota limit | Annual RMB 26,000 | Single shipment RMB 1,000 (RMB 800 for HK/Macau/Taiwan) |
| Tax policy | 0% duty within quota + 70% VAT/consumption tax | Postal parcel tax (three-tier rates) |
| Three-document matching required? | ✅ Required | ❌ Not required |
| Return handling | Can be returned to bonded warehouse | Return shipment handling |
VI. Comparative Analysis of the Four Models
6.1 Model Selection by Enterprise Type
Do you do cross-border e-commerce?
├── B2C Retail (small parcel direct delivery) → 9610 (export) / 1210 (import)
├── B2B Online Trade → 9710
├── FBA/Overseas Warehouse Stocking → 9810
└── Bonded Warehouse Delivery Import → 1210
6.2 Core Comparison Table of the Four Models
| Comparison Dimension | 9610 | 9710 | 9810 | 1210 |
|---|---|---|---|---|
| Direction | Export | Export | Export | Import |
| Applicable entity | B2C sellers | B2B sellers | Overseas warehouse sellers | Cross-border e-commerce importers |
| Declaration method | Manifest + Aggregated | Simplified declaration | Normal declaration | Three-document matching + Manifest |
| Tax refund | ✅ Available | ✅ Available | ✅ After sales | Not applicable |
| Foreign exchange settlement | ✅ | ✅ | ✅ After sales | Not applicable |
| Three-document matching | ✅ | Optional | ❌ | ✅ |
| Logistics mode | Small parcel direct mail | Various | Overseas warehouse first-leg | Bonded warehouse delivery |
| Inventory risk | None | None | Yes (advance stocking required) | Yes (stocking in warehouse required) |
6.3 Policy Trends (2025-2026)
| Trend | Impact |
|---|---|
| 9610/9710 aggregated declaration cycle shortened | Improved tax refund efficiency |
| 9810 tax refund rules further clarified | Reduced policy uncertainty for overseas warehouse model |
| Increased support for cross-border e-commerce overseas warehouses | Expanded application scenarios for 9810 declaration model |
| 1210 positive list expansion | More products can use the bonded import model |
| Possible adjustment to cross-border retail import quota limits | Impacts the market size of the 1210 model |
VII. Practical Guide: How to Start Cross-Border E-Commerce Customs Declaration?
7.1 Basic Requirements
Before starting cross-border e-commerce customs declaration, the following preparations must be completed:
| Requirement | Specific Requirements |
|---|---|
| Customs registration | Cross-border e-commerce enterprises must register with Customs |
| Platform registration | E-commerce platforms must register with Customs |
| Three-document integration | Logistics and payment enterprises must complete data interface integration |
| System readiness | Enterprise ERP or WMS must have data push capability |
7.2 Service Provider Selection
Most small and medium-sized cross-border e-commerce sellers do not connect directly to the customs system themselves, but use the following service providers to complete their cross-border e-commerce customs declaration:
| Service Provider Type | Service Content | Applicable Models |
|---|---|---|
| Cross-border logistics service providers | Integrated logistics + customs declaration | 9610/9710 |
| Overseas warehouse service providers | Stocking + first-leg + declaration | 9810 |
| Customs brokers (cross-border e-commerce specialized) | Agency declaration | 9610/9710/9810 |
| Cross-border payment institutions | Foreign exchange settlement + tax automation | 9610/9710 |
7.3 Industry Scenarios and Model Recommendations
| Industry/Category | Recommended Model | Description |
|---|---|---|
| Apparel & Footwear | 9610 or 9710 | Moderate value, rich SKUs; suitable for both B2C small parcel direct mail or B2B bulk shipments |
| 3C Electronic Accessories | 9610 or 9810 | Small size, high value; FBA overseas warehouse delivery improves buyer experience |
| Home & Daily Necessities | 9810 (Overseas Warehouse) | Large size with high shipping cost; sea freight to overseas warehouse reduces per-unit cost |
| Auto Parts | 9710 or General Trade | Highly specialized, mostly B2B orders; 9710 matches e-commerce platform transactions |
| Pet Supplies | 9610 or 9810 | Rapidly growing category; combination of direct mail and overseas warehouse |
| Outdoor Sports Equipment | 9810 (Overseas Warehouse) | Heavy and bulky with high shipping costs; overseas warehouse model is more suitable |
7.4 Frequently Asked Questions
Q: Can 9610 and 9810 be used together? A: Only one model can be selected for the same batch of goods. Different orders from the same enterprise can use different models.
Q: How long does it take to get a tax refund after cross-border e-commerce declaration? A: For 9610/9710, tax refund can be applied for after aggregated declaration (electronic data pushed to the tax system), generally completed within 1-2 months. For 9810, the refund must be declared after final sales are confirmed.
Q: What are the risks of not doing cross-border e-commerce customs declaration? A: From a compliance perspective, small parcel direct mail without 9610 carries declaration omission risks. From a financial perspective, inability to claim tax refunds and settle foreign exchange increases operating costs. From a customs credit perspective, enterprises with no declaration records cannot establish a credit rating.
Q: Is it necessary to use 9610 for small sellers with few orders? A: Even with few orders, 9610 is recommended. Reasons: ① The three-document matching mechanism ensures compliance; ② Customs credit records can be accumulated; ③ Data foundation is already in place when tax refunds are needed.
Bofeng Logistics provides one-stop cross-border e-commerce customs declaration services, covering all four models: 9610/9710/9810/1210. We have established data integration with multiple cross-border e-commerce platforms and logistics service providers, offering full-process support from declaration to release.
📞 Welcome to call 13075678958 or email info@zhbfwl.com for tailored solutions and quotes.
📖 Next: 2.4 Express Customs Clearance Guide: — KJ1/KJ2/KJ3 Classification and Scope of Application
Further Reading: - 2.1 Comparison of Three Declaration Methods - 2.5 How to Choose a Customs Declaration Method (Decision Flowchart) - 3.5 Full Process for Export Tax Rebate (Cross-Border E-Commerce Tax Refund Rules)
Bofeng Logistics specializes in domestic/international container shipping, Hong Kong/Macau logistics services, and value-added services (trucking, customs brokerage, warehousing, insurance).
Customs brokerage service areas: Zhuhai, Guangzhou, Shenzhen.
Related Logistics Services
Bofeng Logistics offers the following related services, feel free to inquire: