The Ministry of Commerce, Ministry of Industry and Information Technology, Ministry of Public Security, and General Administration of Customs jointly issued Regulatory Notice No. 648, establishing a 180-day vehicle registration threshold: vehicles registered for less than 180 days must provide a manufacturer-stamped After-Sales Service Confirmation Letter before export; without such documentation, export licenses will not be issued. The policy also introduces a negative credit blacklist system for exporters, targeting fraudulent registration certificates and the practice of disguising new vehicles as used vehicles for export arbitrage. The industry is entering a large-scale compliance reshuffle.
Main Text
On November 14, 2025, the four authorities jointly issued the “Notice on Further Strengthening the Management of Used Vehicle Export Operations,” directly addressing the long-standing issue of exporting zero-kilometer nearly-new vehicles as used cars. Under this practice, new vehicles are transferred and registered shortly after production and then exported under the name of used vehicles to obtain circulation and export tax advantages, disrupting domestic and international automotive markets and damaging the overseas reputation of Chinese automotive brands.
Key Mandatory Provisions of the New Policy (Officially Effective January 1, 2026):
1. Vehicle Registration Period Control:
For vehicles registered for less than 180 days, exporters must submit an original manufacturer-issued and officially stamped “After-Sales Maintenance and Service Confirmation Letter,” specifying the destination country, overseas service network, and warranty period. Applications without the required documentation will be rejected directly.
2. Verification of Declaration Information:
Vehicle Registration Certificates, Vehicle Licenses, and export declaration information will be cross-checked through an interconnected national database. Any falsification of mileage, VIN numbers, or ownership transfer records will result in immediate inclusion on the exporter blacklist.
3. Strict Inspection of Modified Vehicles:
Modified used vehicles intended for export must provide a modification filing certificate approved by the Ministry of Industry and Information Technology. Illegally modified vehicles are prohibited from leaving the country.
4. Tiered Penalty Mechanism:
The government will establish a “Negative List of Dishonest Used Vehicle Exporters.” Minor violations will result in official interviews and corrective actions; repeated violations will lead to suspension of export qualifications; exporters involved in document forgery or fraudulent exports will face permanent revocation of business qualifications.During the policy transition period, nearly 30% of small and medium-sized foreign trade companies primarily engaged in zero-kilometer vehicle exports chose to exit the market. Surviving companies abandoned the stockpiling model for nearly-new vehicles and shifted toward exporting genuine used passenger vehicles over three years old, economical gasoline-powered vehicles, and entry-level electric vehicles. At the same time, vehicle manufacturers tightened policies regarding ownership transfers and circulation of new vehicles, eliminating opportunities for grey-market operations at the source.
During the policy transition period, nearly 30% of small and medium-sized foreign trade companies primarily engaged in zero-kilometer vehicle exports chose to exit the market. Surviving companies abandoned the stockpiling model for nearly-new vehicles and shifted toward exporting genuine used passenger vehicles over three years old, economical gasoline-powered vehicles, and entry-level electric vehicles. At the same time, vehicle manufacturers tightened policies regarding ownership transfers and circulation of new vehicles, eliminating opportunities for grey-market operations at the source.
