Import Update: Policy Shift — Key Takeaways for Foreign Businesses

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China Expands Cross-Border E-Commerce Positive List and Raises Tax-Free Threshold for Imported Goods

In a major policy shift effective June 1, 2025, China’s Ministry of Finance has expanded the 跨境电商零售进口商品正面清单 (Cross-Border E-Commerce Retail Import Positive List, kuàjìng diànshāng língshòu jìnkǒu shāngpǐn zhèngmiàn qīngdān) to include 147 new product categories, while increasing the tax-free threshold for personal-use imports from RMB 2,600 to RMB 3,500 per transaction — the largest single expansion since the policy’s inception in 2016.

Policy Details: 147 New Categories and Higher Tax-Free Threshold

The updated positive list, jointly issued by the Ministry of Finance, the General Administration of Customs, and the State Administration of Taxation, adds 147 product categories spanning health supplements, specialty food items, small household appliances, pet care products, and select cosmetics. This brings the total number of categories on the list from 1,476 to 1,623—a 10% increase that opens cross-border e-commerce channels to a significantly wider range of goods.

The tax-free threshold for each transaction has been raised by 34.6%, from RMB 2,600 to RMB 3,500. However, the annual cap per individual remains at RMB 26,000, a level unchanged since 2018. For imported goods valued below the RMB 3,500 threshold, 关税 (tariff, guānshuì) is eliminated entirely, and 增值税 (value-added tax, zēngzhí shuì) is charged at 70% of the statutory rate. Goods exceeding RMB 3,500 but within the annual cap are subject to full taxation. China last expanded the positive list in March 2022 with just 29 new categories; the current 147-category expansion is five times larger.

The policy update reflects Beijing’s broader strategy to stimulate domestic consumption through cross-border e-commerce, while continuing to exercise fiscal caution. The State Council estimates that these changes will generate an additional RMB 12 billion in cross-border e-commerce transaction volume over the next 12 months, with foreign businesses capturing an estimated 35% of that growth.

Impact on Foreign Businesses: Cost Savings and Market Access

The policy shift directly benefits an estimated 12,000+ foreign businesses currently using cross-border e-commerce channels to access the Chinese market, along with thousands more that previously relied exclusively on general trade. By raising the tax-free threshold by 34.6%, the government projects that foreign businesses will collectively save approximately RMB 4.8 billion annually in reduced tariff and VAT costs.

Products in the 147 newly added categories will now qualify for the reduced tax rate without needing to undergo general trade customs clearance, significantly shortening delivery timelines. Under the old regime, general trade clearance for health supplements averaged 15–20 days; cross-border e-commerce clearance now averages 3–5 days. This speed advantage allows foreign brands to test consumer demand with smaller, faster shipments before committing to full-scale general trade importation.

For example, a premium pet food product priced at RMB 3,200 per unit previously exceeded the old RMB 2,600 threshold, incurring tariffs of up to 15% plus full 13% VAT. Under the new RMB 3,500 threshold, the same product enters tariff-free with VAT charged at only 70% — a total savings of approximately RMB 450 per unit. For a mid-size foreign pet food brand selling 10,000 units per month across Chinese platforms, that translates to annual tax savings of RMB 5.4 million.

Health supplements, one of the largest new categories added, represent an especially significant opportunity. Prior to this policy update, many 保健品 (health supplements, bǎojiàn pǐn) required 保健食品注册 (health food registration, bǎojiàn shípǐn zhùcè) under the “Blue Hat” certification process, which could take 12–18 months. The expanded positive list now allows certain supplement categories classified as general food to enter through the cross-border channel without full Blue Hat registration, reducing time-to-market by as much as 14 months.

Compliance Requirements: Registration, Labeling, and Record-Keeping

Despite the expansion, foreign businesses must still meet strict compliance requirements that vary by product category. All imported products must carry 中文标签 (Chinese labels, zhōngwén biāoqian) that comply with GB standards, including mandatory nutrient declarations for food products and usage instructions for household appliances. For the newly added pet food category, labels must include a Chinese-language ingredient list, net weight, production date, shelf life, and distributor information — requirements that previously applied only to general trade imports.

Customs brokers must ensure each import transaction is declared under the correct 海关编码 (HS Code, hǎiguān biānmǎ). The General Administration of Customs has confirmed that HS code misclassification is their top audit priority for the 2025–2026 fiscal year. Additionally, the policy explicitly states that all imports must be for “personal use” and not for commercial resale. While the boundary between personal use and resale remains somewhat ambiguous, customs has provided guidance: shipments exceeding two units of the same product to a single recipient within a 14-day period will trigger automatic review.

Foreign businesses must also ensure that their Chinese cross-border e-commerce platforms — such as Tmall Global, JD Worldwide, and Kaola — are registered with local customs authorities. Each platform must maintain transaction records for at least three years, and foreign sellers must appoint a 代理人 (authorized agent, dàilǐ rén) in China for customs liaison. The agent bears joint legal responsibility for compliance, making partner selection a critical decision.

Comparison Table: Old vs. New Policy

Parameter Old Policy (Pre-June 2025) New Policy (June 2025 Onward) Change
Product categories on positive list 1,476 1,623 +147 (10% increase)
Tax-free threshold per transaction RMB 2,600 RMB 3,500 +34.6%
Annual cap per individual RMB 26,000 RMB 26,000 No change
Tariff on goods below threshold 0% 0% No change
VAT on goods below threshold 70% of statutory rate 70% of statutory rate No change
Last list expansion (scale) March 2022 (+29) June 2025 (+147) 5x larger
Estimated annual tax savings (foreign biz) ~RMB 2.1 billion ~RMB 4.8 billion +128%

3 Critical Pitfalls for Foreign Businesses

Pitfall: Misclassifying products under the wrong HS code when declaring under the new positive list categories. Customs has flagged HS code misclassification as a top compliance risk for 2025. Cost: RMB 50,000–200,000 per shipment in delayed clearance, storage fees at bonded warehouses, and potential administrative fines. Fix: Engage a licensed customs broker to pre-verify HS codes for all 147 new categories before submitting your first declaration. Request a written compliance opinion from your broker and keep it on file.
Pitfall: Failing to update product labels to meet GB standards for newly included categories like pet food and health supplements. Many foreign businesses assume the old label format from their home market will suffice for cross-border e-commerce. Cost: Up to RMB 30,000 per product line if customs rejects the shipment and requires relabeling at a Chinese facility, plus lost sales time of 3–6 weeks. Fix: Submit sample labels to a third-party testing lab for GB compliance review at least 60 days before the first import. Build a label review milestone into your product launch timeline.
Pitfall: Assuming the “personal use” allowance applies to commercial-scale shipments. Some businesses have attempted to circumvent general trade by splitting large orders into multiple sub-RMB 3,500 transactions shipped to the same recipient. Cost: Customs seizure of goods, potential blacklisting of the importer and platform, and penalties of up to RMB 500,000 under the Customs Administrative Punishment Regulations. Fix: Maintain clear documentation of end-consumer purchase records. Never ship more than 2 units of the same product to a single recipient per 14-day period. If you need commercial volumes, switch to general trade importation.

Decision Framework: Cross-Border E-Commerce vs. General Trade

If your product is among the 147 newly added categories and your unit value is below RMB 3,500, choose cross-border e-commerce retail import — it offers lower tax costs, faster customs clearance, and reduced labeling requirements. If your product is not on the positive list, or your unit value exceeds RMB 3,500, choose general trade import — the annual cap of RMB 26,000 per person makes cross-border e-commerce impractical for high-value items sold in volume, and general trade offers unlimited transaction sizes with proper customs declaration. For businesses with both low-value and high-value product lines, maintain parallel channels: cross-border e-commerce for consumer-direct sales under RMB 3,500, and general trade for wholesale and bulk orders.

NEXT STEPS

  1. Review whether your products are on the new positive list. Check the full list of 1,623 categories against your product portfolio. Use our Positive List Verification Tool to confirm eligibility and identify which of your SKUs qualify for the updated tax-free threshold.
  2. Update your customs classification and labeling procedures. The new categories come with stricter GB compliance requirements. Read our Guide to Chinese Product Labeling for a step-by-step compliance checklist specific to cross-border e-commerce imports.
  3. Choose the right import channel for your business model. Cross-border e-commerce and general trade serve different needs for different product types and price points. Compare the two channels in our detailed analysis to determine the optimal strategy for each product line.

— China Gateway 360 —
Remote China market entry support, built around execution.


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