The end of US de minimis treatment didn't just raise costs for cross-border sellers — it changed the dominant export model. The small-parcel, ship-each-order-direct-from-China approach that powered a decade of growth has given way to a "ship first, distribute later" strategy built on overseas warehouses. For Chinese e-commerce exporters, understanding the customs supervision codes behind that shift — especially 9810 — is now a core competitive skill, not a back-office detail.
The Four Codes That Define Cross-Border E-Commerce Export
China Customs operates four special supervision methods for cross-border e-commerce export clearance. Knowing which one fits your model determines your clearance process, your tax treatment, and your rebate eligibility:
- 9610 — direct mail export. The classic small-parcel model: goods ship individually from China to overseas consumers via third-party logistics. Short links, fast, flexible, low cost — and the model most exposed to the loss of de minimis thresholds abroad.
- 9710 — B2B direct export. Cross-border B2B shipments direct to an overseas business buyer.
- 9810 — export to overseas warehouse. Goods ship in bulk to a pre-registered overseas warehouse (owned or rented); the sale to the end consumer happens later, from local stock. This is the model behind Amazon FBA fulfillment and the one most exporters are now moving toward.
- 1210 — bonded e-commerce. Goods enter a domestic bonded warehouse, are listed for sale, and are exported in batches — "batch in, parcel out," useful for pre-positioning stock close to the point of departure.
Why 9810 Is Surging
Under the 9810 model, a domestic enterprise bulk-ships to an overseas warehouse, clears the goods once, and then fulfills local orders from that stock — a B2B2C structure. The advantages line up precisely against the post-de-minimis environment:
- Duty paid once, not per parcel. Instead of a formal entry and duty on every small package, the import is handled as a single bulk entry — removing the per-parcel entry, broker, and bond overhead that now burdens direct shipping.
- Faster delivery. Local stock means 1–3 day delivery rather than 25–40 day ocean transit per order, improving the customer experience and conversion.
- Easier returns and exchanges. Handled in-market rather than shipped back across borders.
The trade-off is real: 9810 requires holding inventory abroad, managing overseas warehouse compliance, and carrying the working capital tied up in pre-positioned stock. A Shenzhen accessories brand sending pallets of its best-sellers to a US warehouse gains two-day delivery and in-market returns, but takes on inventory-turn risk and local compliance duties in exchange.
The Policy Tailwind
This shift has strong official backing. China has made overseas-warehouse construction a foreign-trade priority, with a Ministry of Commerce guideline explicitly promoting cross-border e-commerce exports and overseas-warehouse build-out as a new growth driver. The country now hosts a large network of cross-border e-commerce pilot zones, with the 9710 and 9810 codes specifically designed to streamline clearance. For exporters, the regulatory wind is at your back if you move toward the warehouse model.
Choosing Your Model
Before selecting a supervision code, work through three questions: How large and predictable is your order volume? How much delivery speed does your category require? And can you carry the working capital and compliance load of holding stock abroad? High, steady volume with speed-sensitive customers points to 9810; low or test volume may still favor a consolidated direct approach. The right answer is product- and stage-specific.
How Zhongshen Can Help
We help cross-border sellers select the right customs supervision code, structure bulk 9810 exports to overseas warehouses, handle the clearance and documentation, and align the model with rebate eligibility. If you're moving from small-parcel to warehouse fulfillment, contact our e-commerce desk for a model-and-clearance review.