Currently, China's core policies for automobile exports revolve around the "export license" system, aiming to guide the industry's transformation from "scale expansion" to "quality improvement". Both new and used vehicles require an export license for overseas shipment.
| Implementation Date | Policy Focus | Applicable Vehicles | Core Content |
|---|
| January 1, 2026 | Export License Management for New Pure Electric Passenger Vehicles | Pure electric passenger vehicles with Vehicle Identification Number (VIN) (refer to HS code 8703801090) | Export enterprises must apply for export licenses in accordance with regulations. |
| January 1, 2026 | New Regulations for Used Vehicle Export Management | All used vehicles applying for export | 1. Strictly control new vehicles being exported as used vehicles: For vehicles registered less than 180 days before export, additional submission of "After-sales Maintenance Service Confirmation Letter" issued by the vehicle manufacturer is required.
2. Establish negative list and exit mechanism: Clearly define dishonest behaviors and strengthen dynamic supervision.
3. Regulate modified vehicle exports: Strictly review the authenticity and compliance of modifications. |
| September 2024 (for 2025 application) | Annual Export Qualification Application | All automobiles and motorcycles (including various new vehicles and traditional fuel vehicles) | Manufacturers must annually apply for export license qualifications through designated online systems to competent commerce authorities. |
Recent policies, especially those targeting pure electric new vehicles and used vehicles, demonstrate a clear "precision strengthening" regulatory approach:
The implementation of license management for pure electric passenger vehicles is primarily aimed at standardizing export order. By making automakers responsible for exports, the government ensures product quality control from the source, curbs disorderly price competition, and promotes high-quality overseas development of Chinese new energy vehicle brands.
The core of the new regulations is to combat the illegal practice of "new vehicles exported as used"—strictly controlling the export of new vehicles falsely declared as used to evade taxes or seek improper benefits. By requiring manufacturers to provide the "After-sales Maintenance Service Confirmation Letter", after-sales service responsibilities are shifted forward to protect the rights and interests of overseas consumers and guide the healthy development of the industry.
On December 11, 2025, the Department of Foreign Trade of the Ministry of Commerce and the Quota License Bureau of the Ministry of Commerce issued the "Guidelines on Relevant Matters for Applying for Export Licenses for Used Vehicles and Modified Vehicles (Enterprise Edition)", supplementing and improving the previous policies:
Issuance Requirements for "After-sales Maintenance Service Confirmation Letter" : The Confirmation Letter must be issued by the vehicle manufacturer. Sales companies, overseas sales departments, or overseas authorized dealers under the manufacturer cannot issue the Confirmation Letter on behalf of the company, nor can modified vehicle manufacturers issue it. Additionally, the manufacturer must be listed in the "Announcement of Road Motor Vehicle Manufacturers by the Ministry of Industry and Information Technology" (with consistent names).
Requirements for Exporting Vehicles from Multiple Manufacturers: If a single license includes vehicles from different manufacturers, each manufacturer must issue its own Confirmation Letter.
Vehicle Information Reporting Requirements: Used vehicle export enterprises must report vehicle information (brand, model, registration date, transfer registration date for export, etc.) consistently with the "Motor Vehicle Registration Certificate". For used vehicles whose export license application date is within 180 days (including 180 days) of the vehicle registration date, the "After-sales Maintenance Service Confirmation Letter" must be submitted.
Content Requirements for Confirmation Letter: The Confirmation Letter must include the export destination countries, Vehicle Identification Numbers (VINs), corresponding overseas after-sales service outlet information (address, provider, etc.) for all exported vehicles, and be sealed with the manufacturer's official seal.
Transition Period Policy: Vehicles that have completed transfer registration for export before January 1, 2026, can still apply for export licenses after January 1, 2026, without submitting the Confirmation Letter. Vehicles for which export contracts were signed before January 1, 2026, but have not completed transfer registration for export, must submit the Confirmation Letter.
Clarification of Scope of Application: If modified vehicles are exported as new vehicles, they must apply for licenses in accordance with new vehicle export management regulations.
Additional Reporting Content: Modified vehicle export enterprises must choose between "export by modified vehicle manufacturer" or "export by authorized enterprise of modified vehicle manufacturer", and accurately report vehicle information such as the chassis (or pre-modification complete vehicle) brand, modified vehicle brand, and vehicle model. The vehicle model should be named in accordance with the product model and naming rules in the product parameter sheet of the "Announcement of Road Motor Vehicle Manufacturers and Products by the Ministry of Industry and Information Technology", and reflect the special functions of the modified vehicle, such as "certain type of truck-mounted concrete pump truck", "certain type of truck-mounted crane", etc.
Requirements for Supporting Materials for Licenses:
Highlight pre-modification and post-modification product parts, including detailed descriptions and relevant photos of modified parts; comparison photos of the front, left-front, side, and rear of the vehicle before and after modification, etc. Each vehicle model should have its own modification description.
Photos of the complete vehicle (or chassis) nameplate before and after modification, and the complete vehicle (or chassis) nameplate before modification, which should clearly show all content on the nameplate. Photos of nameplate comparisons must be uploaded for each vehicle (can be combined into one file).
Submit relevant procurement agreements. Refers to procurement agreements or contracts (including invoices) signed by modified vehicle manufacturers when purchasing chassis (or pre-modification complete vehicles) and special devices for exported vehicles. This includes procurement agreements and invoices for chassis (or pre-modification complete vehicles) products, and procurement agreements and invoices for special devices, etc. The procurement quantity of chassis (or pre-modification complete vehicles) and special devices must match the reported export quantity. Corresponding procurement agreements must be uploaded for each vehicle model.
Product announcement parameter sheet. Refers to the product parameter sheet from the "Announcement of Road Motor Vehicle Manufacturers and Products by the Ministry of Industry and Information Technology" obtained by the enterprise (must match the type of products exported by the enterprise). "Product type" refers to "vehicle name" in the "Announcement of Road Motor Vehicle Manufacturers and Products by the Ministry of Industry and Information Technology". For example, if exporting "pure electric box trucks", the announcement for "pure electric box trucks" must be uploaded. Corresponding product parameter sheets must be uploaded for each vehicle model.
National Compulsory Product Certification Certificate. Refers to the national compulsory product certification certificate for the same or similar products (with the same vehicle name). Corresponding national compulsory product certification certificates must be uploaded for each vehicle model.
Proof of compliance with destination country access requirements. Materials include certification certificates and test reports proving that modified vehicles meet the access requirements of the export destination country. If the export destination country has no access requirements, a written statement sealed with the enterprise's official seal should be submitted, along with valid national compulsory product certification certificates and test reports for exported products. Corresponding proof of compliance with destination country access requirements must be uploaded for each vehicle model.
The license application system adjusted according to the "Notice" will go online on December 15, 2025. The old system will be suspended from 17:00 on December 12 to 24:00 on December 14. However, between December 15 and December 31, 2025, when modified vehicle export enterprises apply for 2025 licenses, relevant supporting materials in the license attachment may not be submitted, the "brand" field should select "other brands", and the approved modified vehicle brand should be manually filled in. When enterprises apply for 2026 licenses, they must submit supporting materials in accordance with requirements.
On September 12, 2025, eight ministries and commissions including the Ministry of Industry and Information Technology jointly issued the "Work Plan for Stable Growth of the Automobile Industry (2025-2026)". The main contents related to automobile exports include:
Promote Quality and Efficiency Improvement in Automobile Exports: Encourage automobile and supply chain enterprises to develop and produce products suitable for the destination market, strengthen cooperation with local enterprises, and improve international marketing and after-sales service systems. Leverage the role of industry associations and the Innovation Alliance for International Development of Automobile Enterprises to build a comprehensive public service platform for the internationalization of the automobile industry, providing consulting services on market demand, standard regulations, management policies, etc., in key countries and regions. Guide complete vehicle enterprises to carry out overseas layout in a steady and orderly manner, adapt to local conditions, co-construct and share industrial chain and supply chain systems, and comprehensively improve compliance operation capabilities.
Enhance Financial Service Level for Automobile Exports: Encourage banking financial institutions to increase credit product support for operational and investment financing, and provide convenient local and foreign currency fund settlement services for enterprises. Support financial institutions to provide global fund management products for enterprises in the automobile industry chain. Encourage insurance institutions to optimize export credit insurance business and services for automobiles, provide credit investigation and country risk research services for automobile enterprises, and effectively respond to risks such as exchange rate fluctuations.
Improve Logistics and Transportation System: Develop and improve logistics service guarantee measures for new energy vehicle power batteries, and issue and implement guiding opinions on railway transportation of power batteries. Optimize diversified transportation supply, strengthen supply and demand information docking, promote the construction of infrastructure such as ports and roll-on/roll-off terminals, and improve maritime transportation support capabilities. Guide automobile enterprises and transportation enterprises to establish long-term stable cooperative relationships through cross-shareholding, establishment of joint ventures, etc. Encourage the establishment of multi-brand, high-quality, replicable overseas spare parts warehouses for key components of Chinese brands to reduce comprehensive logistics costs.
According to the notice from the General Office of the Ministry of Commerce on doing a good job in the application for 2026 automobile and motorcycle export licenses, the relevant application requirements are as follows:
Application Form and Process:
This year's application for automobile and motorcycle export licenses will be conducted online.
Manufacturers can log in to the enterprise portal of the automobile and motorcycle export license application system (https://ecomp.licence.org.cn), fill in the application form, upload relevant supporting materials, and submit them to the local commerce authority for review. Enterprises can query the review progress, public results, and announcement list online.
Application Requirements for Pure Electric Passenger Vehicles: Pure electric passenger vehicles (refer to HS code 8703801090) will be subject to export license management starting from January 1, 2026. Enterprises planning to engage in pure electric passenger vehicle export business in 2026 must apply as required, and fill in "passenger vehicles" in the "application vehicle type" field of the system.
Application Requirements for Modified Vehicle Manufacturers: Modified vehicle manufacturers must select "modified vehicle manufacturer" in the "enterprise type" field of the application system, and upload the following materials in the "attachment" field:
Export performance and relevant proof from the previous year. This includes introduction of production capacity, production records of exported vehicles, procurement agreements and invoices for chassis products, procurement agreements and invoices for special devices, export customs declarations, etc.
Description of intended export vehicle models. This includes detailed description of modification content (including photos); information about the enterprise and its products being listed in the "Announcement of Road Motor Vehicle Manufacturers and Products by the Ministry of Industry and Information Technology" and holding valid national compulsory product certification (at least one product announcement parameter sheet and compulsory product certification information must be provided for each vehicle model filled in the "application vehicle type" field); brand information of intended exported vehicles, etc.
Application Time Requirements: Local commerce authorities should complete the preliminary review of application materials for automobile and motorcycle enterprise export licenses and submit them online to the Ministry of Commerce by October 26, 2025, and submit paper materials to the administrative service hall of the Ministry of Commerce.
For automobile export enterprises, compliant operations mainly involve the following processes:
Manufacturers must apply online for qualification through the "automobile and motorcycle export license application system" every year in accordance with the notice from the Ministry of Commerce. The online application system for the 2026 qualification was opened on September 29, 2025. Enterprises must accurately and truthfully fill in relevant information. The Ministry of Commerce will verify the authenticity of application materials. If false materials are found, the enterprise may be notified, warned, suspended or disqualified from engaging in automobile or motorcycle export business in accordance with regulations.
After obtaining export qualifications, enterprises must apply for export licenses for vehicles under specific contracts before each export shipment. This requirement will be implemented for pure electric passenger vehicles starting from 2026.
Special Requirements for Used Vehicle Exports: Enterprises planning to export used vehicles must coordinate with the original vehicle manufacturer in advance to obtain the "After-sales Maintenance Service Confirmation Letter" if the vehicle has been registered for less than 180 days; otherwise, the export license cannot be issued. It should be noted that the registration date refers to the date when the vehicle completes initial registration at the vehicle management office, i.e., the registration date recorded in the "Motor Vehicle Registration Certificate". The 180-day period starts from the registration date at the vehicle management office, not from the vehicle purchase or license plate issuance date.
Special Requirements for Modified Vehicle Exports: Modified vehicle manufacturers must accurately fill in relevant information in the application system and submit proof of modification authenticity as required. If the authenticity of modification cannot be proven, or modified vehicle products are not listed in the announcement of the Ministry of Industry and Information Technology or do not hold valid certification, export licenses will not be issued.
Obstacles for Export of Near-new Vehicles: After the policy blocked the gray channel for near-new vehicle exports, some near-new vehicles previously destined for export shifted to the domestic market, leading to oversupply and a decline in purchase prices. For example, the purchase price of 3-month-old joint-venture sedans dropped from 85% of the new car price to 70-75%.
High-mileage Used Vehicles Become the Main Export Category: Mature vehicles aged 3-5 years have stable conditions and are suitable for overseas demand, becoming the main export category, with purchase prices increasing by 5%-8%.
Increased Threshold for Modified Vehicle Exports: Unrecorded or uncertified models are prohibited from export. Enterprises must ensure modifications meet national standards and provide complete proof of modification authenticity.
Obtain "After-sales Maintenance Service Confirmation Letter" as Soon as Possible: For vehicles that need to be exported within 180 days of registration, contact the manufacturer promptly to obtain the Confirmation Letter.
Shift Focus to High-mileage Used Vehicle Exports: If the Confirmation Letter cannot be obtained, enterprises can choose to engage in legitimate high-mileage used vehicle exports (typically vehicles aged 4-6 years with mileage between 40,000-120,000 kilometers).
Strengthen Compliance Management: Establish a sound compliance management system to ensure accurate reporting of exported vehicle information and compliance of modified vehicle exports with relevant regulations.
Improve Overseas After-sales System: Plan overseas after-sales service outlet layout in advance to ensure timely maintenance and spare parts support for exported vehicles.
In summary, the core of current automobile export policies is "standardization" and "quality improvement". Through the establishment and improvement of the export license management system, China's automobile industry is guided to build long-term, sustainable competitiveness in the global market.
