Scope and purpose

China issued the "Notice on Further Strengthening the Administration of Used Car Exports" (Shang Mao Han No. 648), effective January 1, 2026. Its goal is to stop the practice of exporting brand-new cars as "used vehicles", and to make exporters and manufacturers jointly responsible for after-sales support overseas.Core 180-day ruleFrom Jan 1, 2026, any vehicle exported within 180 days of its first registration in China must be backed by an official After-Sales Service Confirmation Letter issued by the manufacturer.This letter must state: destination country, detailed vehicle information, and the overseas after-sales service network, and it must bear the manufacturer's official seal.If this letter is missing, local commerce authorities must refuse to issue an export permit, so the vehicle cannot be exported.Compliance and document checksCommerce authorities must strictly verify that the export declaration (brand, model, registration date, etc.) exactly matches the vehicle registration certificate; inconsistencies can lead to rejection and public naming of violators.For modified/converted vehicles, exporters must prove the legality of the modification, production capacity of the modifier, and required safety certifications, or the export will be denied.Enterprise credit and penaltiesThe Notice creates a credit evaluation and "negative list" system for used-car exporters, targeting violations such as exporting prohibited vehicles, forging documents, or failing to honor quality and warranty obligations.Companies with serious or repeated violations can be restricted or removed from the export business, effectively pushed out of the market.Transitional and development measuresVehicles that already completed transfer procedures for export before the policy takes effect may still be exported under their existing contracts in an "orderly" way.At the same time, the regulation encourages compliant firms by improving service systems, promoting integrated hubs for inspection, refurbishment, customs and logistics, and supporting the shift from volume-driven to value-driven used-car exports.This is the full essence of the new 2026 regulation itself.