2027 automobile export license application: simple modification channels for modified vehicles are substantially closed

Conclusion first: It is not that modified cars cannot be exported, but the parallel exit path of simply adding a new identity and reporting qualifications according to passenger cars has been filled with the last brick by Document No. 404 of 2026-09-29. Trigger document: Shangbanmao Han [2026] No. 404,"Notice of the General Office of the Ministry of Commerce on Doing a Good Job in the Application of Export Licensing for Automobiles and Motorcycles in 2027"(issued on September 29, 2026, and published on the website of the Ministry of Commerce on September 30, the system was launched on the same day).

1. Chain of facts (by time)

2. Which sentence is blocked?

Original text of No. 404 2 and (3) 3:

"Confirmation Letter of Shared After-Sales Maintenance Services".  For those who apply for the export qualification of 'passenger cars' in simply modified categories such as 'tool vehicle',' patrol vehicle', and 'coach vehicle', they must submit the "Shared After-Sales Maintenance Service Confirmation" issued by the vehicle manufacturer before the modification (i.e. the vehicle manufacturer), stamped with the official seal of the vehicle manufacturer before the modification, promising to provide maintenance technology and spare parts support for exported vehicles, and assist in solving overseas quality and after-sales service problems.

Three levels are advanced, one layer is tighter than the other:

180-day rule

1. First turn off new zero-kilometer cars and take the route of second-hand cars.

648

2. Lock the physical conditions for the export of modified vehicles: certificate of authenticity of the modification + inclusion in the Announcement of the Ministry of Industry and Information Technology + valid CCC certification for the modified vehicle. No certificate will be issued if one item is missing.

no. 404

3. Another responsibility is moved up: If you want to report the qualification according to the passenger car for simple modifications, you must have the original complete vehicle factory stamped and promised to carry out overseas after-sales sales. If the main engine factory stamps parallel exports, it is equivalent to smashing the overseas price system-it will not happen commercially.

→ The channel for exchanging simple additions for the identity of a modified vehicle and applying passenger car export qualifications is effectively closed.

Note: This is not new legislation. Above all, it is the regular annual action of Document No. 318 of 2012, and Document No. 648 has also been implemented on January 1, 2026. The new idea of No. 404 is to move the review process forward and name and simply modify the specific method.

3. Who will survive

Source: Xiong Yu, digital automobile export

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