China Cross-Border E-Commerce Distribution Review: How 1210 and 9610 Models Work for Foreign Brands

China’s cross-border e-commerce (CBEC) regulatory framework has created two dominant customs clearance models that foreign brands can use to sell directly to Chinese consumers without establishing a local entity or going through traditional distribution: Model 1210 (Bonded Warehouse) and Model 9610 (Direct Mail/Express). Together, these models accounted for ¥1.63 trillion (≈$225 billion) in cross-border retail imports in 2024, representing approximately 24% of all retail e-commerce in China.

This review examines how both models work, their respective advantages and limitations, the regulatory requirements each imposes, their cost structures, and which type of foreign brand is best suited for each model. Understanding the difference between 1210 and 9610 is essential for any foreign company evaluating a CBEC-based distribution strategy for China.

The Regulatory Foundation

China’s CBEC framework was established through a series of pilot programs starting in 2013 and formally codified in the 2018 E-Commerce Law. The framework creates a special customs clearance channel for personal-use imports purchased through approved e-commerce platforms, with simplified documentation, reduced duty rates, and expedited clearance processes.

Key regulatory features apply to both models:

• Personal Use Only: All CBEC imports must be for personal use and not for resale. Goods imported through CBEC cannot be sold through domestic Chinese e-commerce platforms (Tmall Domestic, JD Domestic) or physical retail stores without going through general trade customs clearance.
• Positive List: Only products on the CBEC Positive List (last updated in 2022, now covering 1,476 8-digit HS codes) can be imported through CBEC channels. Products requiring CFDA/SAMR registration (most pharmaceuticals, medical devices, infant formula under certain categories) are excluded.
• Purchase Limits: Single transaction limit of ¥5,000 (≈$690) and annual per-person limit of ¥26,000 (≈$3,600). Introduced in 2018, these limits have not been raised despite inflation and market growth.
• Tax Rate: CBEC imports are subject to a reduced tax rate: 70% of the combined import duty + VAT + consumption tax rate. For most consumer goods, this results in an effective rate of approximately 9.1% for general merchandise (vs. 20-35% under general trade).
• No CCC Certification Required: Products imported through CBEC for personal use are exempt from China Compulsory Certification (CCC) requirements, saving foreign brands 6-12 months and significant testing costs.

Model 1210: Bonded Warehouse Clearance

Advantages of Model 1210

• Speed: 1-3 day delivery from order to doorstep, matching domestic e-commerce expectations. This is the model’s single biggest advantage over 9610.
• Lower per-unit shipping cost: Bulk shipping to bonded warehouse is much cheaper than individual international courier packages. Estimated cost: ¥8-15 per unit for 1210 vs. ¥25-60 per unit for 9610 for typical consumer goods.
• Simpler returns: Because inventory is already in China, returns and exchanges can be handled domestically. Returned goods can be stored in the bonded warehouse and reassigned to new orders, subject to customs re-declaration.
• Inventory predictability: Bulk shipments allow for quality inspection and quantity verification before any consumer commitments. Damaged goods can be replaced without affecting customer experience.
• Preferred by platforms: Tmall Global and JD Worldwide strongly encourage 1210 inventory because it enables the fast delivery times that drive consumer satisfaction and platform ratings. 1210-listed products receive higher search rankings on some platforms.

Disadvantages of Model 1210

• Inventory risk: Foreign brands must pre-ship inventory and carry warehousing costs. Slow-moving SKUs can accumulate storage fees (typically ¥5-10 per cubic meter per day in bonded warehouses).
• Higher setup complexity: Requires contracts with bonded warehouse operators, customs clearance agents, and integrated logistics providers. The approval process for new bonded warehouse storage typically takes 2-4 weeks.
• Minimum shipment sizes: Economical bulk shipping to China requires container-load (FCL) or consolidated (LCL) shipments with minimum volumes. This is feasible for established brands but challenging for market testing.
• Positive list dependency: Products must be on the CBEC positive list. This excludes many food supplements, medical devices, and specialized industrial products.
• Warehouse management complexity: Inventory tracking, batch management, expiration date management, and customs reconciliation require a local logistics management capability or a 3PL partner.

Model 9610: Direct Mail/Express Clearance

Advantages of Model 9610

• No inventory pre-positioning: Products ship from existing overseas inventory. No need to pre-ship to bonded warehouses, no warehousing fees, no inventory risk for China-specific stock.
• Perfect for testing: Ideal for brands testing demand for new products in China. A brand can list 50 SKUs, see which ones sell, and only commit to 1210 bonded inventory for the winners.
• Wider product range: Some products not eligible for 1210 (certain food categories, products with short shelf lives, or items requiring cold chain that bonded warehouses cannot handle) can often use 9610.
• Simpler setup: No need for China warehouse contracts, local logistics coordination, or customs clearance agents. Many CBEC platform logistics programs (Tmall Global Direct Shipping, JD Worldwide Direct Mail) handle the entire process end-to-end.
• Lower minimum commitment: Individual packages can be shipped as orders come in. No FCL minimums, no inventory forecasting required.

Disadvantages of Model 9610

• Longer delivery times: 5-14 days versus 1-3 days for 1210. In China’s instant-gratification e-commerce culture, this is a significant competitive disadvantage. Conversion rates for 9610 listings are typically 40-60% lower than comparable 1210 listings.
• Higher per-unit shipping cost: Individual international express shipments cost more than bulk-to-bonded-warehouse logistics. For a 0.5 kg package: approximately ¥25-35 via 9610 vs. ¥8-12 via 1210.
• Complex returns: International returns are prohibitively expensive and logistically difficult. Most 9610 sellers effectively accept that returns are not feasible, which creates consumer trust issues.
• Customs clearance bottlenecks: Individual package processing is slower than bulk bonded clearance, and seasonal peaks (Singles’ Day, Chinese New Year) can cause 2-4 week clearance backlogs.
• Package tracking complexity: Multiple handoffs (overseas carrier → Chinese customs → domestic carrier) create tracking gaps that Chinese consumers find frustrating.

Head-to-Head Comparison: 1210 vs. 9610

The Emerging 9710 and 9810 Models

In addition to 1210 and 9610, two newer models have been introduced for B2B cross-border e-commerce, which are relevant for foreign brands exploring wholesale distribution:

Model 9710 (B2B Direct Export): Designed for Chinese exporters selling directly to overseas buyers through e-commerce platforms. For foreign brands buying from China, this is the model used by Chinese manufacturers selling B2B through Alibaba.com. It provides customs clearance benefits for bulk orders placed online.

Model 9810 (B2B Export to Overseas Warehouse): For Chinese sellers who pre-position inventory in overseas warehouses before selling to foreign consumers. Foreign brands using Chinese manufacturers to produce goods for sale in their home markets may encounter this model when working with Chinese suppliers who use overseas warehouse fulfillment.

While 9710 and 9810 primarily facilitate Chinese exports, foreign brands importing from China should understand these models as they affect how Chinese suppliers structure their CBEC logistics and pricing.

Cost Comparison: Total Landed Cost for a Typical Consumer Product

Note: A product FOB price of ¥100 is assumed for comparison. Actual costs vary by product category, shipping route, and volume. Consumption tax (applied to luxury goods, cosmetics, alcohol, tobacco) is not included in this baseline comparison.

The cost comparison reveals that Model 1210 offers the lowest total landed cost for consumer goods—approximately 12-15% below general trade and 15-20% below Model 9610. This cost advantage, combined with the faster delivery time, explains why 1210 has become the dominant CBEC model, accounting for approximately 68% of CBEC import value in 2024, versus 25% for 9610 and 7% for other models.

Which Model Should Foreign Brands Choose?

Key Regulatory Changes and Trends (2025-2026)

The CBEC regulatory framework continues to evolve. Foreign brands should monitor these developments:

• Positive List Expansion: MOFCOM has signaled a potential expansion of the CBEC positive list to include more health supplement categories and certain medical devices. This would open new opportunities for brands in these regulated categories.
• Purchase Limit Review: Industry associations have consistently petitioned for raising the ¥5,000/¥26,000 limits, which have been unchanged since 2018 despite cumulative inflation of approximately 12%. While no formal announcement has been made, the expanding consumer base suggests limits will eventually be raised.
• Cross-Border Data Requirements: New regulations under the Personal Information Protection Law (PIPL) and Data Security Law are being applied to CBEC data flows. Brands collecting consumer data through CBEC channels (via mini-programs or CRM integrations) must ensure local data storage and cross-border data transfer assessments are completed.
• Integration with Social Commerce: Douyin Global (the cross-border channel of TikTok China/Douyin) has grown rapidly and now processes significant CBEC volume through both 1210 and 9610 models. This creates new distribution opportunities for foreign brands that invest in social commerce content.
• Pilot Zone Expansion: China has expanded the number of comprehensive cross-border e-commerce pilot zones to 165+, covering most major cities and provincial capitals. This means bonded warehouse capacity is available in more locations, enabling faster last-mile delivery across a wider geographic area.

Conclusion: A Powerful Distribution Alternative

The 1210 and 9610 CBEC models have fundamentally changed the distribution landscape for foreign brands in China. For the first time, a foreign company can sell directly to Chinese consumers without establishing a local entity, without a Chinese distributor, and without navigating the complex general trade import regime. The reduced tax burden, simplified customs clearance, and exemption from CCC certification substantially lower the barrier to market entry.

Model 1210 offers the best economics and consumer experience for established products with predictable demand, making it the preferred choice for most consumer goods brands. Model 9610 provides a low-risk testing ground for market entry and niche products. The most sophisticated foreign brands use both models in a phased, hybrid approach—starting with 9610 for market validation and migrating winning SKUs to 1210 for scale.

For foreign companies evaluating China market entry in 2025-2026, CBEC through 1210/9610 is no longer a niche alternative to traditional distribution. It is a mainstream, proven channel that should be considered a primary—rather than experimental—distribution strategy for consumer goods.