Selling into China: VAT, Cross-Border E-Commerce and General Trade
Why a foreign company cannot register for VAT in China — and what to do instead: CBEC under codes 9610 and 1210, the Positive List, general trade, and the domestic-agent requirement.
China is the largest e-commerce market in the world, and the one where the rules are least like anywhere else. For a foreign seller the first thing to understand is also the most counter-intuitive: a foreign company cannot register for VAT in China. There is no equivalent of a non-resident VAT number, and a foreign business cannot issue the fapiao — the official tax invoice on which the whole Chinese system turns. Compliance in China is therefore never a registration exercise. It is a question of which import channel you use, and which Chinese-side infrastructure that channel requires.
China’s indirect tax is VAT, levied at a standard rate of 13% on most goods, with reduced rates of 9% and 6% for defined categories of goods and services. The system has just been recodified: China’s first unified VAT Law took effect on 1 January 2026, consolidating two decades of regulations into a single statute. Corporate income tax is 25%, with a 15% rate for qualified high-technology enterprises.
For an e-commerce seller, the practical decision sits one level above the rate table: general trade import, or the cross-border e-commerce regime.
Route one: cross-border e-commerce (CBEC)
China built a dedicated, deliberately favourable channel for consumer goods sold online to its citizens: the cross-border e-commerce retail import regime, operated through approved CBEC platforms and customs-supervised pilot zones. It is the route most foreign brands should consider first.
CBEC operates through two customs supervision models, identified by their code:
- Code 9610 — direct purchase import (“direct mail”). Goods sit overseas, in the country of origin or an overseas warehouse, and are shipped to the Chinese consumer parcel by parcel after each order. Low set-up, slower delivery, higher per-parcel logistics cost.
- Code 1210 — online-shopping bonded import. Goods are shipped in bulk into a bonded warehouse inside a CBEC pilot zone, held under customs supervision, and cleared and released individually as orders arrive. Faster domestic delivery and better unit economics at volume, at the cost of pre-positioning inventory. (Codes 9710 and 9810 cover B2B export models and do not apply to selling into China.)
The CBEC regime carries three features that matter to a seller’s economics and compliance:
Preferential tax treatment. Within the regime, customs duty is currently set at 0%, and import VAT and consumption tax are levied at 70% of the otherwise applicable rate. The effective tax burden on a typical consumer good is meaningfully lower than under general trade.
Value limits. CBEC retail import is treated as purchase for personal use, and is capped: a single transaction limit of RMB 5,000 and an annual limit of RMB 26,000 per consumer. Within those limits the preferential rates apply; beyond them, the order is taxed as general trade.
The Positive List. Only goods on the official Positive List — 1,476 eight-digit HS codes as of 2026 — may be imported through CBEC. The list covers most popular consumer categories: cosmetics, health supplements, packaged food, apparel, baby goods, small appliances. If your product is not on it, CBEC is closed to you and general trade is the only route.
The decisive advantage of CBEC is regulatory, not just fiscal. Because CBEC goods are treated as personal imports, they are generally exempt from the pre-market registration and certification that general trade demands — the cosmetics filings, food import licences and labelling approvals that can take many months. The trade-off is that CBEC goods are for personal use and may not be resold inside China.
Route two: general trade
General trade is the conventional import channel: goods clear customs as commercial imports, pay full customs duty plus 13% import VAT (and consumption tax where it applies), and enter free circulation. The product can then be sold through any channel — marketplaces, physical retail, distributors — without the value caps or Positive List of CBEC.
The cost is front-loaded compliance. General-trade goods must meet the full Chinese regulatory regime before they can be sold: mandatory product certification where applicable (the CCC mark), Chinese-language labelling, and category-specific approvals — registration or filing with the National Medical Products Administration for cosmetics, import permits for food and supplements. General trade is the right route for a brand building a permanent, resale-based presence; it is rarely the fastest way to test the market.
The Chinese-side infrastructure you cannot skip
Whichever route a foreign seller chooses, China requires a counterpart inside its borders, because the foreign company itself cannot register or invoice.
For CBEC, the overseas seller must be registered with Chinese customs and must operate through the regime’s required participants: a licensed CBEC platform, a domestic customs-clearance agent, a bonded-warehouse or logistics operator, and a payment provider. Customs validates each sale through the “three-document comparison” — order, payment record and logistics record must reconcile — before the parcel is released at the preferential rate.
For general trade, the importer of record must be a Chinese entity with import rights. A foreign brand achieves this either by establishing its own presence — a Wholly Foreign-Owned Enterprise (WFOE) or a foreign-invested commercial enterprise — or by importing through a Chinese distributor or agent.
For tax purposes generally, where an overseas entity conducts a taxable transaction in China, the Chinese purchaser acts as withholding agent, unless the foreign entity appoints a domestic agent to file and pay the tax on its behalf. There is no way to be your own taxpayer of record in China; there is only the question of which domestic party carries that role.
A further practical point: a consumer-facing website hosted in mainland China requires an ICP filing, which itself presupposes a Chinese entity. Most foreign brands sidestep this by selling through established Chinese marketplaces rather than a self-hosted store.
Two typical scenarios
A European or American consumer brand testing China. Its products — say, cosmetics or supplements — are on the Positive List. CBEC is the route: customs registration of the overseas seller, onboarding to a CBEC platform, and a choice between 9610 direct mail to start lean or 1210 bonded import once volume justifies pre-positioned stock. The brand reaches Chinese consumers without the multi-month NMPA registration that general trade would demand, paying duty at 0% and VAT and consumption tax at 70% of rate, within the RMB 5,000 per-order and RMB 26,000 annual limits.
A brand building a permanent, resale presence. It needs general trade and an importer of record — its own WFOE or a Chinese distributor — full product certification and Chinese labelling, and full customs duty plus 13% import VAT. Slower and heavier, but with no value caps, no Positive List constraint, and the right to sell through every channel.
How Servix International helps
Servix International operates a branch in Shenzhen, at the centre of China’s cross-border e-commerce industry. As the global division of an Italian regulated accountancy firm with more than 20 years of cross-border practice, we advise foreign sellers on the entry decision that defines everything else — CBEC or general trade — and then build the structure underneath it: customs registration of the overseas seller, CBEC platform and bonded-warehouse onboarding under codes 9610 or 1210, WFOE establishment where general trade is the goal, appointment of the domestic agent who carries the tax-filing role, and the certification and labelling roadmap for regulated categories. One regulated partner for a market that gives a foreign company no way to represent itself.