China Cross-Border E-Commerce Registration & Setup Guide (2026)

An overseas brand wants Chinese consumers to receive stock from a bonded warehouse. A China-based seller wants to send parcels overseas. A third founder wants to fulfil orders from an overseas warehouse. All three describe cross-border e-commerce in China, but they need different customs codes, filings, tax treatment and logistics.

Begin with the goods, buyer, fulfilment route and whether you sell your own products or operate a platform. Those choices determine whether the project fits 9610, 1210, 9710 or 9810, and shape the WFOE, customs and EDI work.

1. TL;DR: choose the trade model before registering the company

For most foreign founders, the practical sequence is:

1. decide whether the business is importing into China or exporting from China;
2. select the customs supervision model—9610, 1210, 9710 or 9810;
3. register a Chinese limited liability company, usually a WFOE, with a suitable business scope;
4. complete customs registration and cross-border e-commerce enterprise filing through the China International Trade Single Window;
5. add the model-specific account, warehouse or filing required for the chosen route; and
6. activate banking, foreign-exchange, bookkeeping and tax compliance around the real transaction flow.

Three points prevent most early design mistakes:

• A self-operated online seller and a third-party marketplace are not the same regulatory model. The marketplace question is where an EDI licence can become relevant, while the broader ICP filing decision still depends on hosting and the actual service.
• A cross-border e-commerce comprehensive pilot zone is not automatically a bonded zone. In Hainan, 1210 bonded imports still need an approved special customs supervision area and bonded-warehouse arrangements.
• Preferential policies are conditional. Registration in a pilot zone or in Hainan does not by itself create a tax, customs or licensing entitlement.

Hainan adds a distinctive option because it is China’s only province-level, island-wide cross-border e-commerce comprehensive pilot zone. But the national customs and foreign-investment framework still comes first. If the entity decision is not yet clear, compare the wider options in our guide to doing business in China or start with the company registration service.

2. What is cross-border e-commerce in China?

Cross-border e-commerce is trade concluded through an e-commerce platform and fulfilled through cross-border logistics. The definition covers more than a website taking an overseas order. It connects the transaction record, payment, logistics, customs declaration and the company responsible for the trade.

China’s framework separates two directions:

• Cross-border e-commerce import: goods move from overseas to Chinese consumers. A brand may ship each order directly from abroad or place stock in a bonded warehouse before consumers order.
• Cross-border e-commerce export: goods move from China to overseas consumers, business buyers or overseas warehouses. The exporter may send individual parcels, deliver a B2B order directly or pre-position inventory near the end market.

It also separates two digital roles. In a self-operated model, the company sells its own goods. In a platform model, the operator provides online transaction services to third-party merchants. This distinction matters because a self-operated seller is not providing the same value-added telecom service as a marketplace operator. Section 7 explains the EDI licence boundary.

Cross-border e-commerce also differs from general trade because it adds platform transaction data and a dedicated customs supervision model. Product eligibility, order size, buyer type, warehousing, invoices and destination determine which route fits.

3. Market snapshot: why China, and why Hainan?

China had approximately 178 cross-border e-commerce comprehensive pilot zones after the eighth batch approved in April 2025, covering more than 90% of provincial-level administrative regions. These zones support the customs, tax and public-service infrastructure used by qualifying cross-border e-commerce businesses.

Hainan is different in geographic scope. The 2025 approval replaced the former Haikou and Sanya pilot zones with a single pilot zone covering the entire island, making Hainan the country’s only province-wide cross-border e-commerce comprehensive pilot zone.

The local market is still much smaller than China’s national trade base, but the direction is measurable. From January through September 2025, Hainan recorded cross-border e-commerce imports and exports of approximately RMB 1.312 billion, including RMB 1.251 billion of exports. This is a dated provincial snapshot, not a forecast.

Haikou Meilan International Airport shows how one export gateway has scaled. By 13 October 2025, that single port had handled 10.23 million parcels, 8,550 tonnes and declared value of RMB 804 million. Its reported 9610 clearance time fell from 72 hours to 1.04 hours, an efficiency improvement of more than 98%. Those figures describe one airport operation; they should not be treated as a province-wide guarantee for every product or shipment.

The commercial test is whether the company’s buyers, goods, warehouse and supply chain can use Hainan’s island-wide pilot-zone, airport, bonded-area and Free Trade Port infrastructure efficiently.

4. How it works: the four customs supervision codes

The four codes are not product labels. They describe how a transaction and shipment move through customs.

Code	Official model	Typical use	Operating point
9610	Cross-border trade e-commerce	B2C direct-mail retail import or small-parcel export	Short transaction chain; retail export commonly uses list-based release and consolidated declaration
1210	Bonded cross-border trade e-commerce	B2C bonded stock import	Goods enter an approved bonded warehouse in bulk and leave after a consumer order
9710	Cross-border e-commerce B2B direct export	A China-based enterprise sells directly to an overseas business	Goods move by cross-border logistics from the domestic enterprise to the overseas buyer
9810	Cross-border e-commerce export overseas warehouse	Inventory is exported in bulk and stored overseas	The seller fulfils later platform orders from the overseas warehouse; customs overseas-warehouse filing is required

9610: direct mail for retail orders

The 9610 route is widely used for B2C retail. For exports, it supports small parcels under the “release by list, consolidated declaration” approach. The declaration, platform and logistics process must match the local customs system.

1210: bonded stock before the customer orders

Under 1210, goods enter an approved bonded warehouse in bulk. After an eligible consumer order, the parcel leaves the bonded area for domestic delivery. The model requires inventory controls plus the relevant electronic account and warehouse arrangements.

9710 and 9810: two B2B export routes

Under 9710, the goods go directly to the overseas business buyer. Under 9810, stock first goes to an overseas warehouse and is distributed after later orders. A 9810 operator must complete the export overseas-warehouse business-mode filing with customs. A warehouse contract by itself is not that filing.

5. Cross-border e-commerce examples: four models in practice

These four examples show why the supervision code must be selected before documents and systems are built.

Example 1: an overseas consumer brand selling into China

The brand puts eligible goods in an approved bonded warehouse. Each parcel leaves after a Chinese consumer orders. This is a 1210 bonded B2C import model.

Under current retail-import policy and within the applicable personal limits, the tariff rate is temporarily set at 0%, while import VAT and consumption tax are collected at 70% of the statutory amount. The goods are personal-use final goods and cannot be resold in the domestic market. Product eligibility, platform data, warehouse control and the consumer’s transaction limits all matter.

Example 2: a China-based seller sending parcels overseas

A seller ships each consumer order from China directly overseas under 9610 B2C direct-mail export. A qualifying pilot-zone retail exporter may use the “export without purchase invoices” VAT and consumption-tax exemption when all conditions are met. It is not an export refund on unsupported input invoices.

Example 3: a factory selling to an overseas business customer

A factory or trading WFOE sells through a cross-border platform and sends goods directly to an overseas business under 9710 B2B direct export. Contract, platform, customs, logistics and settlement records must describe the same transaction.

Example 4: a brand using an overseas warehouse

A seller exports stock to an overseas warehouse for local fulfilment under 9810. This can improve delivery speed, but adds overseas inventory, reconciliation and warehouse evidence, and requires the customs business-mode filing.

6. Registering a cross-border e-commerce company as a foreign investor

For a foreign investor, the company is the accountable operating centre connecting contracts, customs, payments, tax and platform records. The usual vehicle is a wholly foreign-owned limited liability company, commonly called a WFOE.

Step	What the business does	Key design question
1. Define the model	Confirm import/export, B2C/B2B, customs code, products and buyer	Which party owns goods, contracts and inventory at each stage?
2. Register the WFOE	Choose the name, shareholders, capital, governance, address and business scope	Does the scope expressly cover the planned cross-border e-commerce and trading activity?
3. Complete customs registration	Register the domestic enterprise as the relevant customs declaration unit	Is the registered entity the real exporter or importer in the transaction records?
4. File the enterprise	Use the China International Trade Single Window for cross-border e-commerce enterprise filing	Are the licence, legal-representative and warehouse materials ready?
5. Add model approvals	Configure 1210, 9710 or 9810 requirements	Is a bonded electronic account, B2B registration or overseas-warehouse filing required?
6. Activate tax and foreign exchange	Complete applicable export tax filing, goods-trade foreign-exchange registration and account setup	Do invoices, settlements and declarations reconcile to the same trade flow?

WFOE design comes before filing

The WFOE’s business scope should cover the cross-border e-commerce and trading activities it will actually perform. Its shareholder, registered capital, legal representative and address must also support later bank and customs checks. Use the China WFOE registered-capital guide to model subscribed capital against the five-year contribution obligation.

Foreign-investor documents follow the applicable authentication route. The company then uses the normal process in our Hainan company registration guide. A business licence is only the first operating milestone.

Customs and model-specific setup

For 1210, the operator needs the applicable bonded-import electronic account and a warehouse agreement in an approved special customs supervision area. For 9710, the domestic enterprise completes the B2B export registration required by customs. For 9810, it also files the overseas-warehouse business model. The Single Window filing and underlying warehouse, product and transaction evidence must agree.

The tax route must match the documents. A qualifying “export without purchase invoices” exemption does not involve an input VAT refund. The business also sets up goods-trade foreign-exchange records and current-account settlement; our cross-border fund-flows guide explains why contract, customs and bank evidence must reconcile.

If the foreign founder will actually work in the WFOE, registration does not itself authorize employment. Review the China work visa and work permit guide when designing the management role.

Our company registration team can map the WFOE, business scope and filing sequence around the selected customs model.

7. Foreign ownership rules and the EDI licence question

China applies the foreign-investment negative-list system. Outside the list, foreign-invested enterprises receive national treatment under the same market-access framework as domestic investors. The 2024 national negative list, effective from 1 November 2024, contains 29 special management measures, and the remaining manufacturing foreign-investment restrictions were removed.

The telecom rule is more specific. Value-added telecom services are generally subject to a 50% foreign-equity cap, but the list expressly excludes e-commerce, domestic multiparty communications, store-and-forward services and call centres from that cap. A pure e-commerce business can therefore be 100% foreign owned nationally when no other restricted activity is involved.

Ownership and licensing are separate questions:

• Self-operated seller: the company sells only its own goods and does not provide an online trading platform to third-party merchants. That activity does not itself constitute a third-party value-added telecom platform service, so the EDI question generally does not arise from the self-operated sales function.
• Third-party marketplace: the operator provides online data processing and transaction services to other merchants. It generally needs an EDI licence for online data processing and transaction processing.

Since April 2024, Beijing, Shanghai, Hainan and Shenzhen have participated in a value-added telecom opening pilot that removes foreign-equity caps for specified services including EDI, IDC, CDN and ISP. The pilot does not remove the licence. The operator still needs the applicable MIIT trial approval and must operate within its approved business and area.

Content restrictions remain for internet news, online publishing, online audiovisual programs, internet culture operation other than music, and certain public information services. The e-commerce exception does not cover a restricted content business.

The China market-entry consulting service is the right starting point when the project combines marketplace functions, data infrastructure or regulated content.

8. Tax framework for cross-border e-commerce

The tax outcome follows the direction, goods, consumer limit, documentation and eligibility conditions. The following is a policy summary, not tax-planning advice.

Scenario	Current policy framework	Main conditions or boundary
Retail import to an individual	RMB 5,000 per transaction and RMB 26,000 annual limit; temporary 0% tariff and import VAT/consumption tax at 70% of the statutory amount	Personal-use final goods; product and transaction must fit the retail-import framework
Single item above RMB 5,000 but within annual limit	May use the retail channel when the order contains one indivisible item, but taxes are collected in full at the goods rate	Transaction counts toward the annual total
Retail export without valid purchase invoices	VAT and consumption-tax exemption may apply	Pilot-zone registration and platform record, e-commerce customs declaration, and goods not excluded from export tax relief
Eligible retail exporter under approved collection	Deemed taxable-income rate of 4%	This is a taxable-income rate, not a 4% corporate income tax rate; all statutory conditions must be met
Encouraged Hainan enterprise	Conditional 15% corporate income tax rate through the end of 2027	Hainan registration and substantive operation, encouraged activity and normally at least 60% qualifying main-business revenue

Retail imports

Within the applicable limits, the temporary tariff rate is 0%, while import VAT and consumption tax are assessed at 70% of the statutory amount. If the annual limit is exceeded, the excess is managed under general-trade rules. Goods purchased under the retail-import policy are for the consumer’s personal use and cannot be resold domestically.

Retail exports from a pilot zone

The “export without purchase invoices” policy can exempt VAT and consumption tax when the exporter is registered in the pilot zone, records the required export information on the local online comprehensive service platform, declares the goods through the pilot-zone customs authority and does not export goods excluded from tax relief.

For corporate income tax, an eligible retail exporter without valid purchase invoices may use a uniform 4% deemed taxable-income rate under the approved-collection policy. The 4% figure is applied to determine taxable income; it should not be described as a 4% tax rate. Eligibility and reporting still have to be documented.

Hainan’s 15% corporate income tax route is separate. Cross-border e-commerce is an encouraged activity, but the company must satisfy the applicable catalogue, qualifying-revenue and substantive-operation conditions. Read our Hainan 15% CIT guide before including that rate in a forecast. Ongoing bookkeeping, return filing and evidence controls can be scoped through the bookkeeping and tax service.

9. Hainan FTP: the extra layer for e-commerce

Hainan’s island-wide pilot-zone status applies across the province, but a comprehensive pilot zone is not the same as a bonded zone. The 1210 bonded-stock function operates through approved special customs supervision areas such as Haikou Comprehensive Bonded Zone and Yangpu Bonded Port Area. Imported bonded inventory must enter the approved area and remain subject to its account and warehouse controls.

The Hainan Free Trade Port adds two separate customs-policy layers after island-wide special customs operations began on 18 December 2025.

Approximately 6,600 zero-tariff lines

The Hainan import-export policy uses a negative-list approach to import taxation. The zero-tariff scope expanded to approximately 6,600 tariff lines, around 74% of all tariff lines. This FTP policy is not the same thing as the retail-import treatment for a consumer order. Entity eligibility, the taxable-import catalogue, the “first line/second line” movement and the final destination still matter. Our Hainan zero-tariff policy guide explains the boundary.

The 30% value-added processing rule

An encouraged-industry enterprise can qualify for import-duty exemption when goods containing imported materials are processed in Hainan, achieve at least 30% value added, and then enter the mainland. Import VAT and consumption tax remain payable according to the rules.

Value-added rate =
  (mainland sale price - imported material cost - domestic material cost)
  ÷ (imported material cost + domestic material cost) × 100%

Eligible value added can accumulate across filed upstream and downstream processors. Minor processing—such as mixing, relabelling, repackaging, splitting packages, shelling, simple grinding or simple cutting—does not qualify by itself. Moving parcels through Hainan is not enough.

The Hainan import-export and 30% value-added guide covers both the formula and customs evidence. Use it again when deciding whether Hainan is a sales base, a bonded-import gateway or a genuine processing location rather than just a registration address.

10. Compliance essentials and the setup next step

Cross-border e-commerce creates a data trail across the platform, payment provider, logistics provider, customs, bank and tax records. Compliance is largely the discipline of making those records describe the same real transaction.

Three-document matching and declaration integrity

Retail imports use the operational “three-document matching” process: order data, payment data and logistics data are aligned with the customs declaration list. Product, buyer, price, payment and parcel information must be authentic and consistent for the applicable verification and release process.

For exports, the declared owner, goods, value, buyer, platform record, warehouse movement and settlement also need to reconcile. Using another company’s name to declare goods, routing business receipts through personal accounts, leaving sales in an empty offshore company, inventing unsupported input costs or claiming an improper export refund creates tax and customs risk.

Authorities can use tax big-data cross-verification across platform, customs, bank and payment records. Inaccurate declarations can lead to inspection, penalties, detention of goods and a lower customs credit rating. Product data, platform reconciliation, warehouse records, invoices, settlement evidence and returns should work as one system. See the China fapiao and VAT invoice guide.

A practical launch checklist

Before filing, confirm:

• the import or export direction and the chosen 9610/1210/9710/9810 code;
• who owns the goods and signs the customer, warehouse and logistics contracts;
• whether the company sells its own goods or provides a marketplace to third parties;
• the WFOE scope, address, capital and management arrangement;
• customs registration, Single Window filing and model-specific approvals;
• the warehouse, platform, payment and logistics data interfaces;
• the applicable import, export, invoicing and corporate-income-tax treatment; and
• monthly reconciliation between sales, declarations, bank receipts and accounts.

For recurring accounting and filing, see the bookkeeping and tax service. If the project still needs a broader China-entry decision, send the planned products, buyer type, platform role, warehouse route and settlement flow through our contact page or book a 30-minute consultation.

Primary policy references used in this guide

• State Council approval of the eighth batch of comprehensive pilot zones
• GACC Announcement No. 75 of 2020 on 9710 and 9810
• Retail-import transaction limits and tax framework
• Retail-export VAT and consumption-tax exemption
• Approved enterprise-income-tax collection for qualifying retail exporters
• 2024 national foreign-investment negative list
• MIIT value-added telecom opening pilot
• Hainan 30% value-added processing customs rules

Frequently Asked Questions

What is cross-border e-commerce and how does it work in China?

Cross-border e-commerce is trade concluded through an e-commerce platform and fulfilled through cross-border logistics. In China it has two directions: retail import, where overseas goods are sold to Chinese consumers, and export, where goods move from China to overseas consumers, business buyers or warehouses. The operating route depends on the buyer, goods, logistics and customs supervision code.

What is the difference between the 9610, 1210, 9710 and 9810 customs codes?

9610 is used for B2C direct-mail retail trade; 1210 is bonded B2C retail, with stock entering a bonded warehouse before consumers order; 9710 is B2B direct export from a Chinese enterprise to an overseas business; and 9810 is export to an overseas warehouse before onward delivery. A company using 9810 must complete the overseas-warehouse business-mode filing with customs.

Can a foreign company own 100% of a cross-border e-commerce business in China?

Generally yes when the activity is outside the applicable foreign-investment negative list. The 2024 national negative list exempts e-commerce from the 50% foreign-equity cap that otherwise applies to value-added telecom services, and manufacturing restrictions were removed. Ownership does not replace customs, market-access, EDI or sector approvals required by the actual model.

Do I need an EDI license to sell products cross-border in China?

A company selling only its own goods does not normally provide a value-added telecom platform service, so that self-operated model does not itself require an EDI licence. A platform providing online transaction services to third-party merchants generally needs an EDI licence. Hainan is one of four opening-pilot regions where the EDI foreign-equity cap was removed, but the operator still needs the relevant MIIT pilot approval.

How do I register a cross-border e-commerce company in China as a foreign investor?

Define the import or export model, register a WFOE with the correct scope, complete customs registration, file the cross-border e-commerce enterprise through the Single Window, and obtain model-specific approvals. A 1210 operator needs the relevant bonded arrangements, while a 9810 operator needs an overseas-warehouse filing. The company also completes applicable tax and foreign-exchange setup.

What taxes and duties apply to cross-border e-commerce in China?

Under current policy, qualifying retail imports within the RMB 5,000 per-transaction and RMB 26,000 annual limits use a temporary 0% tariff rate while import VAT and consumption tax are collected at 70% of the statutory amount. Qualifying pilot-zone retail exports without valid purchase invoices may receive VAT and consumption-tax exemption, and eligible exporters may use a 4% deemed taxable-income rate. Hainan’s conditional 15% corporate income tax policy is separate.

What is “three-document matching” (三单对碰) for cross-border e-commerce imports?

It is the operational alignment of order, payment and logistics data with the customs declaration list. The platform, payment provider and logistics provider transmit their respective records, and the information must be authentic and consistent for the applicable customs verification and release process. Reliable interfaces and reconciliation controls are therefore part of the compliance design.

Why set up a cross-border e-commerce business in Hainan Free Trade Port?

Hainan is China’s only island-wide cross-border e-commerce comprehensive pilot zone. A qualifying business can combine the national pilot-zone framework with Hainan operating options, including bonded 1210 activity in approved special customs areas, a conditional 15% corporate income tax rate for encouraged enterprises with substantive operations, approximately 6,600 zero-tariff lines and the separate 30% value-added processing duty exemption when its conditions are met.

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Disclaimer: This guide is for general information and does not constitute legal, customs, tax or investment advice. Policies, product eligibility and local implementation can change. Confirm the current filing, licence, customs, tax, warehouse and foreign-exchange requirements with the competent authorities before acting.