China Taxes the Metal on the Way Out, Then Zeroes It Once the Metal Has a Shape

AI Summary

China’s 2026 tariff plan applies export duty to 107 goods, 68 of them at a provisional rate. For copper and aluminium the pattern is deliberate: unwrought metal at 30 percent, scrap at 15, and every wrought product at zero. The form of the metal decides the duty.

The coverage of this plan went one way. Every English summary reported the import side — 935 goods with provisional import rates below the most-favoured-nation level, 8,972 tariff lines, zero tariffs for 43 least-developed countries. Those are real and worth knowing.

The export side is the half that raises a buyer’s cost, and it went unreported. It is also arithmetic rather than policy commentary, because the schedule is published row by row and the rates are on the page.

What happened

The Customs Tariff Commission of the State Council issued 税委会公告2025年第11号 on 26 December 2025, published on 29 December, setting the 2026 tariff adjustment plan with effect from 1 January 2026. The announcement is short; the substance is in seven annexes. Annex 3 is the export goods tariff schedule.

Two numbers frame it. The official interpretation states that China continues to levy export duty on 107 goods, of which 68 are subject to a provisional rate. Counting the annex row by row returns exactly 107 entries, so the count and the schedule agree.

The import side of the same plan is what got covered:

Six entries carry an ex marker, which the annex’s own note defines: within that single tariff line, the specific product description governs which rate applies rather than the line as a whole. It is the schedule’s way of taxing one grade of a metal at a different rate from another grade sharing the same code.

Two notes on the annex are worth reading rather than skimming. The ex note is the first. The second says that except for ex lines, the product names are indicative only, and the binding scope is the product scope in the 2026 Import and Export Tariff corresponding to the code. So classification follows the tariff, not the annex’s descriptive text.

Export duty — a tax a country collects when goods leave it, distinct from the import duty the destination country collects when they arrive. China’s is levied on the export, so it enters a buyer’s cost through the FOB quotation rather than at the destination border, which is why a landed-cost model built purely on import tariffs misses it.

Why now

Three reasons this belongs in a sourcing decision this quarter rather than in an archive.

The pattern is the point, and it is stable. Rows 38 to 71 cover copper, rows 72 to 75 nickel, rows 76 to 100 aluminium, rows 101 to 104 zinc, rows 105 to 107 antimony. Across the metals, the schedule taxes the raw and the semi-finished and zeroes the wrought. Copper cathode sits at a 30 percent nominal rate with a 10 percent provisional; copper waste and scrap at 30 with 15; and then every wrought copper line — wire, bar, rod, sections, plate, sheet, strip — carries a 30 percent nominal rate overridden by a zero provisional rate. Aluminium repeats it at a lower level: unwrought non-alloy aluminium at 30 percent, aluminium waste and scrap at 30 with a 15 percent provisional, and every wrought aluminium line at 20 percent nominal with a zero provisional.

Some goods have no provisional relief at all, and those are the expensive ones. Ferrochrome sits at 40 percent with no provisional rate, which is why the announcement names it — 继续对铬铁等107项商品 — as the lead example of the whole list. Steel and cast-iron scrap runs at 40 percent across seven lines. Bone meal and bone waste at 40. Tin ore at 50 percent nominal, cut to a 20 percent provisional. A buyer whose input is on the unrelieved part of this list is paying an export duty that no destination-side analysis will show.

And the direction of the plan is consistent with the rest of 2026. China is keeping raw material at home and exporting the manufactured form, while separately withdrawing the export VAT rebate on 249 product lines described in the export rebate analysis. An export duty on the input and no rebate on the output is a coherent industrial position: process it here, or pay to take it away.

So what

The arithmetic is straightforward once the export duty is in the model, because it is a percentage of FOB, exactly like an import tariff — just collected at the other end.

Four conclusions, and the first one changes a purchasing decision.

The form of the metal decides the duty, not the metal. Copper cathode at $8,000 per tonne carries $800 in Chinese export duty. Copper wire at $8,600 per tonne carries none. On a ten-tonne order that is $8,000 of duty that exists on one shape of the same metal and not the other. A buyer who can specify the wrought form and buy it as wire, strip or profile avoids a charge that a buyer of cathode pays, and the comparison is decidable from the published schedule rather than from a supplier’s explanation.

Export duty can be the larger half of the total. On unwrought aluminium at a 25 percent destination rate, the Chinese export duty of $780 still exceeds the importing country’s $680. On copper cathode or ferrochrome with a free destination rate, the export duty is 100 percent of the duty bill — the destination contributes nothing and the cost is entirely created on the way out. A landed-cost model that begins at FOB and adds the destination tariff understates these goods by the whole charge.

Ferrochrome is where it bites hardest, and it has no relief. At 40 percent with no provisional rate, a $1,200 per tonne FOB becomes $1,680 before freight. That is the highest rate on the schedule bar tin ore’s nominal 50 percent, and it applies to a ferroalloy used in stainless steel. Buyers with ferrochrome in the bill of materials are the group for whom this schedule is least avoidable and most worth modelling.

And scrap sits between raw and wrought, which is not an accident. Copper scrap at a 15 percent provisional and aluminium scrap at 15 means the schedule discourages exporting metal in any unprocessed state while taxing the fully raw form hardest. The rates read as a processing ladder: 30 percent for the ingot, 15 for the scrap, zero for the product.

So classify the form before negotiating the price. Three moves: pull the tariff code for the exact form of the material you buy rather than its generic name, because the schedule and the annex’s ex note both turn on the specific description; model the Chinese export duty as a line in the landed cost, since it is a percentage of FOB and computes like any tariff; and where your specification allows a wrought form, price it against the raw form. The gap can exceed the entire destination tariff.

For you

• Buyers of unwrought or semi-finished metals from China: your input is on the taxed part of the schedule. Check the provisional rate for your exact code before assuming the nominal rate applies — copper cathode’s 30 percent nominal is actually 10 percent payable, and aluminium of 99.995 percent purity or above carries a zero provisional rate that lower grades do not.
• Buyers who buy the same metal in a wrought form: your input carries no Chinese export duty. That is a structural advantage worth naming in a negotiation, because the supplier’s raw-material cost includes a charge your purchased form does not attract.
• Buyers with ferrochrome, steel scrap or bone materials in the bill of materials: these carry 40 percent with no provisional relief. Rebuild the landed cost from FOB with the export duty included, and expect the exercise to move the number materially.
• Buyers comparing China against another origin for a raw material: the comparison is not like for like while one origin charges a 30 percent export duty and the other does not. Put both sides of the duty ledger in the model before concluding that one origin is cheaper.

The data point

FAQ

Is an export duty different from a tariff on imports?

It is the same kind of instrument applied at the other end of the transaction. An import duty is collected by the destination country when goods arrive; an export duty is collected by the country of origin when they leave. China’s export duty is charged on the FOB value, so it lands inside the price a supplier quotes rather than appearing on your own customs entry, which is why a landed-cost model built only on import tariffs understates goods that carry one. Rates on the 2026 schedule run from a zero provisional rate to a 50 percent nominal rate on tin ore.

Why does the same metal have different rates depending on its form?

Because the schedule is an industrial policy instrument as well as a revenue one. Taxing the raw form and zeroing the processed form keeps the processing margin and the associated employment inside China while still permitting the finished material to be exported competitively. The pattern is legible across the metals in Annex 3: unwrought copper 30 percent nominal, copper scrap 30 with a 15 percent provisional, and every wrought copper line at zero provisional. Aluminium repeats it one level lower. A buyer choosing between forms of the same metal is choosing which side of that policy to sit on.

What does the ex marker in the annex mean?

The annex defines it in its own note: for a line marked ex, the provisional or export rate within that tariff line applies according to the specific product description rather than to the line as a whole. In practice it lets one grade of a metal be taxed differently from another grade sharing the same code — high-purity cathode copper appears both as a zero provisional rate and as a 5 percent rate under different descriptions in the same line. A buyer relying on a generic code without reading the description on the entry can therefore be charged a rate they did not expect.

Does the plan also change what I pay on the way in?

Yes, and favourably. The same plan grants provisional import duty rates below the most-favoured-nation rate on 935 goods, adds national subheadings for intelligent bionic robots, bio-aviation kerosene and forest ginseng to bring the total to 8,972 lines, continues conventional rates under 24 free trade agreements with 34 partner economies, and gives 43 least-developed countries zero tariff on 100 percent of their lines. It also cancels provisional rates and restores the MFN rate on micro motors, printing machines and sulphuric acid, so not every change runs one way.

The point

A tariff schedule is a statement of what a country wants to export, and China’s 2026 version says it plainly: raw metal carries 30 percent, scrap carries 15, and the finished form carries nothing. That is a sourcing map, not a revenue measure, and it is published row by row in an annex that the English coverage of this plan did not open. The practical consequence is that the shape of the metal you buy now has a price attached that is larger than most destination tariffs — $8,000 on a ten-tonne copper order, decided before a single rate is negotiated.