News
9710/9810 Regulatory Upgrade: Gray Operations Are No Longer Feasible!
Author:
LMT
Release time:
2026-03-23
Source:
LMT International Logistics Services Co., Ltd.
Recently, industry feedback indicates that Yantian Port has launched a special inspection campaign targeting the 9710 (Cross-border E-commerce B2B Direct Export) and 9810 (Cross-border E-commerce Export to Overseas Warehouses) supervision modes. Regulatory focus has extended from pre-clearance to post-clearance checks.
The old practice of considering a shipment "completed" once it leaves the country may no longer work. Customs now places greater emphasis on whether goods are actually sold after export, with the authority to conduct follow-up audits at any time.
01 Why the Strict Inspections Now?
This special inspection on 9710 and 9810 modes is closely related to long-standing gray operations in the industry.
Issues such as exporting under another entity’s name, fictitious transactions, underreporting prices, and data inconsistencies have been frequent. Some enterprises mix declarations under modes 0110, 9710, and 9810 to evade supervision. With the implementation of tax policies including Circulars No. 15 and 17, the room for traditional "gray declarations" has been significantly reduced, and supervision has fully shifted toward authenticity and compliance.
Notably, market rumors that "switching to 0110 can reduce inspection probability" are unfounded. Customs has explicitly stated that the special campaign targets trade authenticity, regardless of declaration mode.
02 How Inspections Are Conducted
Yantian and Nanshan Ports have recently intensified inspections on cross-border e-commerce export containers, especially implementing post-release verification (DR mode) for cleared goods.
If selected for inspection, enterprises must submit a complete set of supplementary documents, including backend store screenshots, sales pages, overseas warehouse agreements, inventory certificates, bank statements, and genuine orders.
Required documents vary by mode:
- 0110: Foreign trade contracts, commercial invoices, foreign exchange payment vouchers, domestic procurement contracts, and bank statements;
- 9710: Shipment order numbers, store registration screenshots, sales page screenshots, and platform inventory screenshots;
- 9810: Additional genuine Amazon order records.
Nanshan Port has also tightened supervision. In cases of customs audit holds or container locks, enterprises must either cancel the declaration and withdraw goods, or have their legal representative appear in person with original ID to cooperate with the process.
Behind this inspection drive is a fundamental shift in regulatory logic from "front-end facilitation" to "back-end penetrating verification". Tax authorities require 9810 businesses to adopt the rule of "tax refund upon departure, settlement upon sale", creating a closed-loop verification of sales, foreign exchange collection, and tax refund data. Meanwhile, while simplifying declaration procedures, Customs has strengthened reviews of the authenticity of electronic data such as orders, logistics, and funds. The integration of order flow, logistics, capital flow, and invoice flow has become the basic threshold for enterprise compliance.
03 Clearance ≠ Completion
Pursuant to the Customs Law and relevant inspection regulations, Customs retains the right to examine relevant documents within 3 years from the date of goods clearance.
This means clearance is not the end—declaration liabilities persist long-term. If audited, enterprises must fully substantiate trade authenticity. Missing documents or inconsistent data may trigger customs clearance cancellation or penalties.
Operationally, enterprises must also guard against multiple risks:
- Consolidated shipment risk: If any item in a consolidated container is flagged for inspection, the entire container may be detained;
- Documentation risk: Lack of supporting materials such as orders, contracts, or statements will result in failed verification;
- Data risk: Discrepancies between declared information and actual transactions easily trigger alerts;
- Overseas warehouse risk: 9810 mode requires complete warehousing agreements and address details; otherwise, operations may be deemed abnormal.
04 How Enterprises Should Respond
Faced with stricter regulation, enterprises must immediately conduct internal audits:
- Comprehensively review 9710/9810 businesses to ensure authentic and consistent data across orders, logistics, and funds;
- Improve documentation systems, maintaining complete records of contracts, invoices, customs declarations, platform orders, and foreign exchange vouchers;
- Ensure four-flow integration, aligning data across order, capital, logistics, and invoice flows;
- Select declaration modes based on actual business, avoiding mixed or incorrect usage;
- Establish long-term compliance mechanisms, retaining documents for no less than 3 years and conducting regular risk self-inspections.
This special inspection at Yantian Port sends a clear signal: cross-border e-commerce export regulation has entered a new era of full-link traceability. The era of relying on information gaps and gray operations is ending. Future competition will hinge not only on price and efficiency but also on compliance capabilities. Only by adhering to genuine trade, improving data systems, and building compliance capacity can enterprises achieve sustainable growth in the complex and ever-changing cross-border landscape.
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