In order to crack down on the long-standing gray export model of "new cars disguising used cars," China has implemented stricter automobile export regulations starting from January 1, 2026. The core requirement is that all vehicles planned to be exported must be registered in China for 180 days before leaving the country. This measure may have a profound impact on the Russian market, which is highly dependent on China's imports, and even cut off the supply of our country's new cars in Russia. For vehicles that apply for export less than 180 days (inclusive) before the registration date, local commercial authorities shall guide local enterprises to supplement the "After-Sales Maintenance Service Confirmation Form" issued by the vehicle manufacturer, which includes the export country, vehicle information, information on outlets providing after-sales services, etc. and stamped with the official seal of the production enterprise. Export licenses will not be issued to vehicles that cannot provide the above materials. For vehicles that have gone through transfer registration and export procedures before the implementation date of the notice, enterprises must be guided to perform the contract well and export it in an orderly manner.

Vulnerabilities and hidden dangers of gray exports:

The new regulations are intended to correct a long-standing common phenomenon: disguising new zero-kilometer cars as used cars for export. These cars were immediately shipped abroad after short-term registration in China, bypassing official dealers and providing no after-sales guarantees. This practice has been widely used when supplying goods to Eurasian Economic Union (EAEU) countries, including Russia. This operating mode takes advantage of loopholes in the single vehicle evaluation conclusions and the vehicle structural safety certificate (which we have previously reported), and does not apply for a vehicle type approval certificate in accordance with the requirements of the Customs Union technical regulations.

Formally speaking, the manufacturer assumes no responsibility for the follow-up of such vehicles within the Eurasian Economic Union (EAEU): it provides neither a warranty nor supplies original parts. It is obvious that many brands are very dissatisfied with this because the vehicles have been sold and the brand name has been used, but they have completely lost control of quality and service.

This loophole has created a huge "gray" import market, especially for brands that are not willing or have not yet had time to join the Eurasian Economic Union.

These changes involve both new cars and brand new vehicles disguised as used cars.

The new regulations and three measures are taken simultaneously to narrow export channels:

In response to the above-mentioned industry chaos, the new measures have been fundamentally adjusted in three aspects, significantly raising the export threshold of China's automobiles:

I. Introduce a 180-day "cooling-off period". From the first registration of a vehicle in China to its export overseas, the interval must be no less than half a year. In the past, the fast supply channel of "buying a car today, deregistering tomorrow and shipping it immediately to Russia" has been completely closed. A six-month wait is a hard requirement that cannot be ignored.

II. Add mandatory documents. When exporting a car, a "After-Sales Service Center Confirmation Letter" stamped by the manufacturer must be provided.

This is essentially the manufacturer's written recognition that the vehicle will still receive official after-sales service after leaving the country. Without this confirmation, the vehicle will not be able to be exported.

III. Graded export license system. China's automobile export licenses are divided into two levels. A type of license is used for the export of used cars and can be applied by many trading companies. The other category is for new cars and is limited to car manufacturers or their official authorized agencies (companies).

Summary:

In general, these measures together constitute a strict regulatory system, effectively curbing the large-scale gray export of "new cars disguised as used cars" and returning the initiative and control of automobile exports to manufacturers and the country.

Starting from January 1, 2026, any China car wishing to enter Russia must meet the registration period requirement of at least 180 days. This regulation was jointly issued by the Ministry of Commerce, the Ministry of Industry and Information Technology and the General Administration of Customs, demonstrating China's determination to pursue quality assurance in automobile exports.

Source: SVYAZ

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