In-depth Interpretation of 2026 New Auto Export Regulations: Vehicles Are NOT Banned from Export, but Compliance Is Upgraded!

I. Core Contents of the New Regulations: Upgraded Management of Three Categories, Clear Red Lines and Requirements

Battery Electric Passenger Vehicles: Exclusive Export License Management to Eliminate Fake Branding

1. Core Requirement: Exporters of battery electric passenger vehicles must apply for an export license from the Ministry of Commerce; customs clearance is strictly prohibited without a valid license.
2. Eligible Applicants: Only automakers and their authorized enterprises, which may only export vehicles of their own brands, completely eliminating violations such as fake branding and license plate cloning.
3. Application Method: Fully online processing. Enterprises shall submit applications and upload materials via the “Enterprise Terminal of the Automobile and Motorcycle Export License Declaration System”. Local commerce authorities conduct preliminary reviews before submitting to the Ministry of Commerce for final approval.
4. Regulatory Purpose: Strengthen automakers’ brand responsibility and overseas after-sales obligations, enabling Chinese battery electric passenger vehicles to enter the global market with formal qualifications.

Used Vehicles: 180-Day Red Line as Key, Strict Consistency Review for License Applications

1. 180-Day Red Line Rule: For vehicles registered for less than 180 days to be exported, a After-Sales Repair Service Confirmation Letter issued by the automaker (including destination country, VIN, overseas after-sales network information, and stamped with the automaker’s official seal) must be submitted; no license will be issued without this document. Vehicles with transfer registration completed before December 31, 2025 pending export may perform contracts orderly without the confirmation letter, under a reasonable transition period.
2. Information Consistency Requirement: Vehicle brand, model, registration date and other information declared in the export license must be fully consistent with the Motor Vehicle Registration Certificate. Registration/transfer dates must be separately filled in the license attachment. No license will be issued for incorrect or missing information; repeat offenders will be publicly notified.
3. Dynamic Management Mechanism: A dynamic management and withdrawal mechanism for used vehicle export enterprises will be established. Local commerce authorities conduct credit evaluations against the Negative List of Dishonest Behaviors in Used Vehicle Exports. Violators will be interviewed, ordered to rectify within a time limit; serious offenders will be restricted from license applications, and new enterprises established by their legal representatives and affiliates will undergo comprehensive assessment.
4. Document Specification: The After-Sales Repair Service Confirmation Letter may only be issued by automakers listed in the Announcement of Road Motor Vehicle Manufacturers by MIIT; sales subsidiaries, overseas departments or authorized dealers have no such authority.

Modified Vehicles: Compliance Modification as Precondition, Announcement + Certification Mandatory

1. Core Qualifications: Modified vehicles must be listed in MIIT’s Announcement of Road Motor Vehicle Manufacturers and Products and obtain China Compulsory Certification (CCC).
2. Document Requirements: When applying for an export license, complete proof of modification authenticity must be submitted, including modification descriptions and photos, chassis/original vehicle nameplate photos, procurement agreements, announcement parameter pages, and destination country access certificates.
3. Enterprise Declaration: Modified vehicle manufacturers shall select the “Modified Vehicle Manufacturer” category in the declaration system and additionally upload annual export performance of the previous year and detailed modification descriptions of intended export models.

II. Practical Guidelines: Action Plans by Entity to Avoid Risks

Automakers & Formal Export Enterprises: Qualification Self-Inspection + Complete Documents + Improved After-Sales Service

1. Qualification Check & License Application: BEV exporters shall immediately confirm inclusion in the Ministry of Commerce’s eligible enterprise list. Those without licenses shall complete online applications promptly with true and complete information.
2. Advance Document Preparation: For vehicles under 180 days of registration for export, obtain the stamped After-Sales Repair Service Confirmation Letter in advance to ensure consistency with vehicle information. Modified vehicle exporters shall organize full sets of announcements, CCC certificates and modification proofs.
3. Strict Information Verification: Assign dedicated staff to cross-check license declarations with the Motor Vehicle Registration Certificate to avoid errors causing application failure.
4. Credit Compliance: Conduct self-inspections against the Negative List to avoid credit blacklisting.
5. Overseas After-Sales Improvement: Establish or connect with after-sales networks in target markets, prepare spare parts and technical support to meet regulatory requirements and enhance global competitiveness.

Used Car Dealers & Individual Exporters: Stay Within Red Lines + Cooperate with Formal Entities + Verify Procedures

1. Abide by the 180-Day Rule: Refuse “zero-kilometer used car” violations; do not stock or export vehicles under 180 days of registration without the required confirmation letter.
2. Pre-Export Procedure Verification: Ensure complete and authentic information on the Motor Vehicle Registration Certificate; confirm export processes with cooperative enterprises to avoid license delays.
3. Cooperate Only with Qualified Entities: Reject unlicensed intermediaries; partner only with formally qualified enterprises to reduce operational risks.
4. Track Industry Updates: Monitor credit evaluation results and avoid non-compliant enterprises under rectification to protect legitimate rights and interests.