Agency Freight Responsibility in 2026 Export Tax Rebate: Policy Deconstruction and Enterprise Response

In 2026,many foreign trade enterprises in Shanghai are often troubled by one question when handling export tax rebate: who should actually pay the agency freight?Recently,the 2026 Detailed Rules for Export Tax Rebate Declaration> (hereinafter referred to as the "Detailed Rules") jointly released by the State Taxation Administration and the General Administration of Customs has provided clear guidance on this issue.With more than 20 years of experience in foreign trade agency and practical experience serving over 300 local enterprises in Shanghai,Zhongshen deconstructs the core of the policy,analyzes its impact on enterprises and provides implementation suggestions.

I.Core Deconstruction of 2026 Policy: 3 Key Points

The provisions on "agency freight" in the Detailed Rules do not directly clarify "who pays",but regulate the issue through three dimensions: scope definition,tax rebate connection and settlement rules.The details are as follows:

• Point1:ComplianceDefinitionofAgencyFreight:Itonlyrefersto"theinternationaltransportationfeeprepaidbytheforeigntradeagencyfortheexportenterpriseanddirectlyrelatedtothespecificexportedgoods".Threetypesofdocumentsmustbeprovidedsimultaneously:agencyagreement(clarifyingthecorrelationofthefee),VATinvoiceissuedbythetransportationcompany(issuedtotheexportenterpriseortheagency),andcustomsmanifestdata(matchingthecargotransportationinformation).Ifanydocumentismissing,thefeewillbeidentifiedas"non-compliantexportexpense"andcannotbeincludedintaxrebatecalculation.
• Point2:CorrelationBetweenTaxRebateRateandFeePresentation:In2026,thetaxrebaterateformainstreamexportcommoditiessuchasmechanicalandelectricalproductsandtextilesremainsat13%,butitisrequiredthat"agencyfreightmustbelistedseparatelyintheexporttaxrebatedeclarationsystem"—ifdeclaredtogetherwiththepaymentforgoods,thetaxauthoritywillreturnthedeclarationmaterialsdueto"vagueexpenseproportion";iflistedseparatelywithcompliantdocuments,thefeecanbeincludedintaxrebatecalculationaccordingtothetaxrebaterateofthecorrespondingcommodity.
• Point3:AccountSpecificationforCross-borderSettlement:Theforeignexchangereceiptandpaymentofagencyfreightmustbedeclaredthroughtheaccountof"agencyservicefeeundertradeitem",andmustnotbemixedintotheaccountof"goodstradepayment".Startingfrom2026,theStateAdministrationofForeignExchangewillsharetheaccountdatawiththetaxauthority.Ifthewrongaccountisused,thetaxrebateauditwillbedelayedby3-5workingdays.

II.Impact of the Policy on Enterprises: Coexistence of Opportunities and Challenges

Manager Pan from Zhongshen has received many inquiries from foreign trade enterprises recently.Mr.Su,who owns an electronic product export enterprise,said: "Previously,agency freight was either mixed with agency service fees or directly borne by the agency.Now that the policy is clarified,we actually feel a bit uncertain." Combined with actual cases,the policy impact can be divided into two aspects:

(1) Opportunities: Reduce declaration errors and improve tax rebate efficiency

① Clear document requirements reduce enterprises’ "trial and error cost": In the past,some enterprises failed to provide agency agreements,resulting in agency freight being excluded from the tax rebate scope; after the 2026 Detailed Rules clarified the requirement of 3 types of documents,enterprises can prepare in advance and reduce the declaration rejection rate.According to data from Zhongshen,among the enterprises served in the first quarter of 2026,the rejection rate due to agency freight issues dropped from 18% last year to 7%.

② Standardized cross-border settlement accounts simplify the process: Previously,mixing agency freight into payment declaration often led to cross delays between foreign exchange verification and tax rebate audit; after the account specification was clarified in 2026,some enterprises reported that the average tax rebate cycle was shortened from 12 working days to 9 working days.

(2) Challenges: Higher compliance requirements require refined contract management

① Contract clauses need to be clearly agreed: If the agency agreement does not specify "who bears the agency freight","fee standard" and "document provision time",it may lead to subsequent disputes — for example,Mr.Zhong from a clothing export enterprise once encountered that the agency delayed invoicing on the grounds of "no agreement on document provision",which affected his tax rebate process.

② Higher requirements for financial document sorting: Invoices,manifests and agreements of agency freight need to be sorted separately to avoid confusion with payment documents.Some small and medium-sized foreign trade enterprises often make the mistake of "combined listing" because their financial staff are not familiar with the new policy.

III.Zhongshen’s Practical Agency Service: Help Enterprises Seize Opportunities and Overcome Challenges

In response to the 2026 policy changes,Zhongshen has launched targeted agency services based on more than 20 years of industry experience.The details are as follows:

Enterprise Pain Point	Zhongshen’s Solution	Practical Effect
Unclear contract clauses,prone to disputes	The contract review team led by Manager Pan provides free agency agreement optimization for enterprises,clarifying clauses such as "agency freight bearer,document provision requirements,invoicing time limit"	Among more than 50 enterprises with optimized agreements since 2026,no tax rebate delay caused by contract issues has occurred
Irregular agency freight document sorting	We have established an "agency freight document template".The documentation team led by Ms.Lan assists enterprises to sort invoices,manifests and agreements by category,ensuring separate listing meets policy requirements	The one-time passing rate of enterprise declaration increased from 65% to 92%
Wrong cross-border settlement account affects tax rebate	The foreign exchange team led by Supervisor Jin guides enterprises to declare under the account of "agency service fee under trade item",and synchronizes data with the tax authority	The average tax rebate cycle is shortened by 3 working days

In addition,Zhongshen also provides "policy early warning service" for enterprises — it pushes notifications of policy changes related to agency freight every month.For example,we helped enterprises adjust processes in advance for the supplementary regulations on "cross-border e-commerce agency freight" issued in some regions in March 2026.

IV.Practical Suggestion: Sort out agency freight ledger once every quarter

Combining policy requirements and actual enterprise cases,Manager Pan from Zhongshen suggests: Export enterprises can sort out the "agency freight ledger" at the end of each quarter in 2026,which includes: ① The freight bearer specified in the agency agreement; ② Whether the invoices,manifests and agreements of the current quarter’s agency freight are complete; ③ Whether the cross-border settlement account is correct.If any problem is found,enterprises can contact the agency for adjustment in advance to avoid affecting the tax rebate progress.