Automotive Export Policy

Automotive export policies refer to the regulatory frameworks, administrative measures, and management systems established by Chinese authorities to govern vehicle exports and bolster the international competitiveness of Chinese automobiles. In recent years, China's vehicle export volume has grown exponentially, reaching 5.096 million complete units in 2025—a 65.3% year-on-year surge. However, this rapid expansion has also brought challenges, including fragmented exporters, unstructured operating models, and aggressive price undercutting. In response, regulatory bodies have rolled out a series of new policies aimed at shifting the industry from volume-driven growth to quality-focused development.

New Car Exports: Pure Electric Passenger Cars Brought Under Export Licensing Regime

On 26 September 2025, China's Ministry of Commerce (MOFCOM), Ministry of Industry and Information Technology (MIIT), General Administration of Customs, and State Administration for Market Regulation (SAMR) jointly announced that export licensing controls will be enforced on pure electric passenger vehicles effective 1 January 2026. The regulation applies to "other passenger vehicles equipped solely with electric drive motors and bearing a Vehicle Identification Number (VIN)" (Customs Tariff Code: 8703801090).

The new policy establishes the following regulatory framework:

Exporter Eligibility: Only automotive manufacturers (OEMs) and their officially authorised trading partners are eligible to apply, and they are strictly limited to exporting pure electric passenger cars produced under their own proprietary brands. Companies must be gazetted under MIIT's "Announcement on Road Motor Vehicle Manufacturing Enterprises and Products", and vehicles must obtain China Compulsory Certification (CCC). Vehicle manufacturers without established overseas after-sales service and repair networks are strictly prohibited from exporting directly or authorising third-party exports.

Export Licence Application: Companies must submit applications via the official automotive and motorcycle export licensing portal during the annual application window. Export eligibility will be granted following an initial vetting by local commerce bureaus and final approval by MOFCOM. Coachbuilders and modified vehicle manufacturers must provide additional documentation verifying the authenticity and legitimacy of vehicle modifications.

Policy Objectives: The regime aims to plug illicit, unauthorised export loopholes, stem destructive price wars, and drive carmakers towards value-driven exports. Wu Songquan, Chief Engineer at the China Automotive Strategy and Policy Research Centre, noted that this policy systematically overhauls the export ecosystem across three key pillars: enforcing OEM brand accountability, elevating overseas after-sales support, and curbing predatory pricing.

Used Car Exports: Stricter Controls on "Zero-Kilometre Used Cars"

On 11 November 2025, MOFCOM, MIIT, the Ministry of Public Security, and the General Administration of Customs jointly issued the "Notice on Further Strengthening the Administration of Used Car Exports", coming into force on 1 January 2026. Key measures include:

Stringent curbs on pre-registered new cars exported as used cars (commonly known as "zero-kilometre used cars"): From 1 January 2026, vehicles registered for 180 days or fewer prior to the export application must provide an official "After-sales Maintenance and Repair Service Confirmation Letter" issued and stamped by the vehicle OEM. This document must specify the destination country, vehicle details, and authorised after-sales service network information. Failure to produce these credentials will result in an immediate rejection of the export licence application.

Standardised export licence procedures: Exporters must ensure all declaration data is accurate and fully declared; vehicle make, model, initial registration date, and pending export transfer registration date must match the official "Motor Vehicle Registration Certificate" exactly.

Dynamic enterprise monitoring and market exit mechanisms: Regulatory bodies will maintain ongoing compliance checks and dynamic oversight based on the "Negative List of Dishonest Conduct in Used Car Exports", penalising and barring non-compliant players.

Tighter scrutiny on vehicle conversions and coachbuilt exports: Exporters of modified vehicles must provide authentic conversion proof; all units must be registered under MIIT's vehicle catalogue and carry valid CCC certification.

Behind these policies is the rampant practice of "zero-kilometre used cars"—where parallel grey-market traders acquire brand-new cars in China without OEM authorisation and export them as pre-owned units. This practice disrupts official overseas pricing strategies, while end-buyers frequently face voided factory warranties, untethered connectivity/telematics, and lack of technical support. Between 2021 and 2024, China's used car export figures skyrocketed from 15,000 to 430,000 units, the vast majority of which were parallel grey-market exports.

Export Licensing Filing System

According to the "Notice on Implementing the 2026 Automotive and Motorcycle Export Licensing Filing" issued by MOFCOM in September 2025, the 2026 filing exercise is conducted fully online, with the system operational since 29 September 2025. Vehicle manufacturers must access the enterprise portal of the automotive and motorcycle export licensing platform to complete their submissions and attach the required supporting documents.

Under the filing guidelines, vehicle conversion and modification manufacturers must select "Modified Vehicle Manufacturing Enterprise" under the "Enterprise Type" field. They must provide historical export track records from the preceding year (including manufacturing facility profiles, production logs for export units, rolling chassis purchase contracts and invoices, auxiliary equipment invoices, customs declaration forms, etc.) alongside comprehensive technical dossiers of the models to be exported (including detailed conversion specifications, MIIT product catalogue approvals, CCC compliance certificates, etc.).

Policy Impact

The roll-out of these 2026 regulations marks a decisive transition in China's automotive export governance—moving from loose oversight to end-to-end, full-chain regulation. Integrating pure electric passenger cars into the core export licensing regime alongside tightened used car export rules creates a comprehensive oversight framework spanning both brand-new vehicles (including NEVs) and pre-owned units across both manufacturing and trading sectors. The China Association of Automobile Manufacturers (CAAM) highlighted this move as carrying "immense practical and strategic significance for the global expansion of Chinese automobiles."

For small and medium-sized parallel exporters, business models must undergo an overhaul—either by securing official dealership or distributor mandates from OEMs, or by pivoting to genuine, bona fide used car trading. Industry observers broadly agree that these measures will weed out non-compliant players and accelerate China's automotive export evolution from sheer volume expansion to high-value global leadership.