The export of used cars involves three key aspects: vehicle sources, qualifications, and profits.

There are three documents, with three effective dates. Four tasks must be completed by 2027.

In October 2026, everyone involved in exporting used cars was calculating the same thing: whether roads could still be used for transportation.

From September 29th to October 12th, two national-level documents were implemented within two weeks. The rules that will take effect on January 1st this year are becoming even stricter. These three measures target the same goal: in the past, regulators asked whether a company had the necessary qualifications for export. Now, they ask who will repair the vehicles after they’re exported and who will be responsible for setting prices.

First Measure: Vehicle Sources

The first measure focuses on vehicle sources, specifically “zero-mile used cars.” According to the notice issued by the Ministry of Commerce, the Ministry of Industry and Information Technology, the Ministry of Public Security, and the General Administration of Customs, starting from January 1, 2026, vehicles that are less than 180 days since registration must submit an official “After-sales Repair Service Confirmation” from the vehicle manufacturer. Those who cannot provide such a document will not be granted an export license. This measure has been in place for over nine months, effectively eliminating loopholes exploited by companies using fake qualifications.

The second measure concerns qualifications. It targets “paper-based after-sales services” and “simple modifications.” According to the notice No. 404 [2026], there are three significant changes in the export licensing process for automobiles and motorcycles in 2027.

1. After-sales service points must be verifiable. Applications must include contracts with authorized agents, business licenses or maintenance permits from the country of destination, official documentation proving maintenance capabilities, as well as photos, equipment records, personnel certificates, and spare parts logistics. Automobile manufacturers must provide proof of at least 50 service points.

2. Vehicles modified into “passenger vehicles” such as “tool vehicles,” “patrol vehicles,” or “training vehicles” must submit an official “Shared After-sales Repair Service Confirmation” from the original vehicle manufacturer.

3. A new requirement is added: companies must commit to compliance with industry regulations regarding pricing and avoid disrupting market order through unfair competition. When applying for licenses, companies must fill out information accurately regarding prices and other relevant details.

The deadlines are clear:

【October 28, 2026】Local commerce authorities must complete preliminary reviews and submit reports online. Applications submitted after the deadline or without corrections will not be accepted.

【October 23, 2026】This is the deadline for online applications as required by the Shenzhen Municipal Commerce Bureau. Companies usually have their own deadlines earlier than those set by the ministry level.

The third measure focuses on profits. It targets the tax benefits available for exported new energy vehicles. According to Announcement No. 29 of 2026 issued by the Ministry of Finance and the State Taxation Administration, starting from April 1, 2027, the VAT refund rate for new energy vehicles will be reduced from 13% to 9%, based on the date of customs declaration.

Second Measure: Common Goals of the Three Measures

Combining these three documents reveals a unified goal: the core of export qualifications is shifting from “sole ownership” to “ability to fulfill obligations.”

At the vehicle source level, requiring manufacturers to provide official stamps ensures that the authenticity of vehicles is verified. At the qualification level, requiring verifiable service points and having OEMs take responsibility for modified vehicles ensures that service capabilities are backed by solid evidence. Finally, requiring compliance with pricing regulations makes overseas competition a prerequisite for obtaining licenses. Together, these measures use administrative measures to guide companies from “low-price marketing” towards “long-term operations.”

For compliant operators, these measures serve to eliminate obstacles. For intermediaries who rely on price differences, these measures involve restructuring costs.

After these three measures, the business remains the same, but the threshold has changed from “having vehicles” to “having after-sales services, having actual performance, and having price discipline.” The policy deadlines are clear: October 28th is the qualification deadline, and March 31st, 2027, is the tax refund deadline. Using these dates as milestones is more reliable than any prediction.

Source: Digital Automotive Export, Xiong Yu

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