Automotive Repair Technical Information Disclosure

Automotive repair technical information disclosure refers to a regulatory framework requiring vehicle manufacturers to release technical repair data for models sold on the market to all repair workshops and consumers without distinction, discrimination, or delay, via accessible formats, convenient channels, and at reasonable fees. This policy is designed to break carmakers' monopoly over repair know-how and replacement parts supply, foster fair competition across the vehicle servicing and repair sector, and protect consumers' right to freely choose where to service or repair their vehicles.

Legal Basis and Background

The statutory foundation for the automotive repair technical information disclosure system rests primarily on Article 55 of the "Law on the Prevention and Control of Atmospheric Pollution", which empowers transport authorities to implement the disclosure regime and penalise non-compliant carmakers.

For years, vehicle manufacturers maintained an "authorised" distribution model for technical repair data and spare parts. Official 4S centres leveraged this technical monopoly, leaving independent workshops—which represent over 95% of all repairers—unable to legitimately obtain proprietary repair data. This led to anti-competitive market practices and severely restricted consumer choice. As of 2014, there were approximately 460,000 motor vehicle repair businesses nationwide, of which authorised 4S centres accounted for around 20,000, representing less than 5% of the total. In response, the Ministry of Transport, alongside eight other government bodies including the Ministry of Environmental Protection and the Ministry of Commerce, jointly introduced the "Administrative Measures for the Implementation of Automotive Repair Technical Information Disclosure" (Jiao Yun Fa [2015] No. 146), which took effect on 1 January 2016.

Core Principles and Requirements

Information disclosure is anchored on the principles of fairness and impartiality, integrity and trustworthiness, voluntary disclosure, user convenience, and intellectual property protection. Vehicle manufacturers bear primary responsibility for disclosure and are held accountable for the authenticity, accuracy, and completeness of all published information.

No distinction, no discrimination, and no delay are the core tenets of the framework—manufacturers are strictly prohibited from erecting technical barriers to restrict competition, lock out third parties, or monopolise the automotive repair market. Vehicle manufacturers must ensure that independent workshops have access to the exact same web-based technical portal and information provided to their authorised service centres.

Disclosure Channels: Information must, in principle, be made accessible online. Manufacturers are required to provide technical repair data to users via proprietary or third-party online disclosure platforms.

Scope of Disclosure and Exemptions

Mandatory technical repair data to be disclosed by manufacturers includes: Vehicle Identification Number (VIN) decoding logic; workshop service manuals (covering wiring diagrams, electronic control unit DTC fault codes, emissions control systems, body dimensions, and wheel alignment specifications); parts catalogues (with original part names, trademarks, and part numbers); ECU software and hardware version identifiers; vehicle ECU reprogramming and re-flashing data; dedicated diagnostic, testing, and repair tool/equipment specifications; vehicle homologation data; technical service bulletins (TSBs); and vehicle recall notices along with defect rectification procedures.

Exemptions from disclosure comprise: data relating to vehicle immobiliser/anti-theft programming and configuration (including car key transponders); core low-level system code that prevents powertrain and emissions factory programmes, original calibration data, and raw OBD parameters from being overwritten or tampered with; trade secrets of carmakers and component suppliers; and other proprietary data protected by national laws and regulations.

Implementation Timeline

• Before 31 December 2015: All vehicle manufacturers must file technical repair information disclosure records with the Ministry of Transport

• Newly approved models: From 1 January 2016, CCC-certified passenger cars and buses/coaches must disclose information within 6 months of market launch; from 1 January 2017, commercial lorries and prime movers must disclose within 6 months of market launch

• Existing models: Before 1 January 2017, release technical repair data for CCC-certified passenger cars and buses/coaches launched after 1 July 2008, as well as commercial lorries and prime movers launched after 1 January 2015

• Information retention period: At least 10 years from the vehicle model's initial market launch date

Paid Access and Fee Regulations

Vehicle manufacturers may offer technical repair data as a paid service and establish tiered pricing structures based on access levels; fees must be fair and reasonable, and charging additional fees based on the volume of vehicle model searches or queries is strictly prohibited. In addition, carmakers must incorporate a free-access section on their portals to provide consumers with routine vehicle maintenance and servicing guides for every model.

Supporting Industry Standards

In 2022, the Ministry of Transport rolled out the industry standard JT/T 1413-2022 "Specification for Automotive Repair Technical Information Disclosure", which took effect on 13 April 2022. Formulated to resolve persistent issues uncovered during oversight—such as poor data quality, superficial technical depth, and inadequate repair guidance—this standard standardises the structural and content requirements for vehicle maintenance and workshop service manuals.

Regulatory Oversight and Legal Liabilities

The Ministry of Transport is responsible for guiding, coordinating, and overseeing the disclosure regime, establishing an expert panel alongside relevant agencies to handle policy consultation, technical appraisals, and dispute mediation. Manufacturers failing to disclose or adequately maintain repair information face statutory penalties from the Ministry of Transport and the Certification and Accreditation Administration of China (CNCA). Where improper repairs or quality defects result from erroneous or deficient technical data disclosed by the manufacturer, the vehicle manufacturer shall bear full legal liability.