The General Administration of Customs and the State Taxation Administration jointly issued Announcement No. 256 of 2025, clarifying that starting January 1, 2026, the “Certificate of Tax Payment/Non-Refund for Export Goods” will undergo electronic data network verification.
This represents not merely a system integration but a fundamental shift in regulatory approaches—the information barriers between tax authorities and customs have been completely dismantled, delivering a precise blow to the “buy-and-export” model that has long relied on information asymmetry.
“To clear customs, first check the tax invoice”—this is the core operational logic of the new regulations!
In the past, tax and customs systems operated independently, allowing enterprises to circumvent oversight through “buying export declarations”—where the actual cargo owner did not file customs declarations and the declarant had no genuine exports.
Diese Reform ist die erste ihrer Art:
❶ After the tax authority issues the “Certificate,” the electronic data is synchronized to customs in real time.
❷ Customs automatically retrieves and compares this data during the declaration process;
❸ Without a valid certificate, customs clearance cannot be completed.
In simple terms, the previous approach was “clearance first, verification later,” which may have encouraged companies to take chances. Now it's “verification first, clearance later.” If data doesn't match up logically, goods are immediately held up at the port. This marks an unprecedented elevation of tax compliance in the export process.
Why is the “buy-and-export” approach no longer viable?
The essence of “buying the bill for export” lies in exploiting the disconnect between tax and customs information. By separating the cargo owner from the customs declaration entity, it circumvents oversight, making it difficult to trace and prone to abuse.
Tax data and customs declaration data now synchronize in real time, forming a closed-loop system:
❶ Each Certificate corresponds to only one customs declaration form, ensuring full traceability throughout the process;
❷ Once data is used, it shall not be invalidated or reissued.
❸ The “bill-paying” chain will be laid bare, and relevant enterprises will face rigorous scrutiny and heavy penalties.
This marks the official end of the “buy-and-export” model, with compliance now being the only viable path forward.
How can foreign trade enterprises save themselves?
☑ Enterprises must complete self-inspections in advance, verify the matching status between the “Certificate of Tax Paid/Unrefunded for Export Goods” and customs declarations, and ensure document consistency and compliance with declaration standards.
☑ Establish compliant export customs declaration and tax refund procedures as soon as possible to avoid non-compliance risks.
