Requirements and precautions for exporting used cars
Requirements and precautions for exporting used cars

Requirements and precautions for exporting used cars

2025-11-05
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Used cars refer to automobiles (including three-wheeled vehicles, low-speed freight vehicles, i.e., original agricultural transport vehicles, the same below), trailers and motorcycles that are traded and transferred from the time they are registered until they reach the national mandatory scrapping standard.

used cars

Export requirements

I. Enterprise Qualification (Registration) Enterprises applying to conduct used car export business must meet the following conditions:

(I) Manufacturing Enterprises:

  1. Registered in the People’s Republic of China and possessing independent legal person status;
  2. Listed in the Ministry of Industry and Information Technology’s “Announcement of Road Motor Vehicle Manufacturers and Products”;
  3. Exporting products manufactured by the enterprise itself;
  4. Operating legally and in accordance with regulations, complying with laws and regulations concerning safety production, environmental protection, taxation, customs, and foreign exchange management, with no outstanding illegal or irregular activities and no serious breaches of trust.

(II) Distribution Enterprises:

  1. Registered in the People’s Republic of China and possessing independent legal person status;
  2. Possessing fixed business premises and used car display and sales locations, and having experience in automobile sales or trade;
  3. Possessing used car appraisal and assessment capabilities, employing at least 3 appraisal and assessment professionals;
  4. Operating legally and in accordance with regulations, complying with laws and regulations concerning safety production, environmental protection, taxation, customs, and foreign exchange management, with no outstanding illegal or irregular activities and no serious breaches of trust.

Enterprises that pass the review can apply for a used car export license in accordance with the “Application Materials for Export License” requirements in the “Announcement of the Ministry of Commerce and Other Five Departments on Matters Related to the Export of Used Cars”.

Export registration: Valid for one year.

II. Ministry of Commerce Requirements: 1. Completely fill in the Vehicle Identification Number (VIN) in the system; 2. Fill in the name of the used car exporting company in both the “Exporter” and “Shipper” fields on the license; 3. Select “Used” in the “Commodity Condition” field; 4. Accurately fill in the vehicle brand and model in the “Specifications and Grade” field; Note: The relevant content should be consistent with the “Motor Vehicle Registration Certificate”; 5. The “Importing Country (Region)” should be the final destination of the goods listed in the contract. If the vehicles are exported to special customs supervision areas such as comprehensive bonded zones within China, the “Importing Country (Region)” should be China; 6. Used car export licenses are managed on a “one batch, one license” basis. Companies can apply for a maximum of 20 used electric vehicles under the same commodity code on the license application form; 7. The declared quantity must be consistent with the quantity on the license, and customs clearance must be completed in one go; Risk point: If the declared quantity is inconsistent with the quantity on the license and a new license is not applied for, the undeclared vehicles will not be able to apply for a license again and will not be able to be exported again. 8. Within two months of completing customs clearance procedures for the used car, the company must apply to the public security traffic management department for cancellation of registration, submitting the export customs declaration and relevant documents.

Reminder: 1. VIN code entered incorrectly, such as “O” instead of “0”. Note: The VIN code is 17 digits long, consisting of Arabic numerals and uppercase Roman letters. The letters “I”, “O”, and “Q” cannot be used in any of these codes.

  1. If some vehicles on the customs declaration form have not been exported due to factors such as the vehicle’s condition not meeting loading requirements or the shipping company reshipping cargo, the original certificate must be deleted and a new application submitted. An application must also be made to customs to amend the customs declaration form.

If a company illegally cancels vehicle registration in advance, it will be impossible to reissue certificates for the canceled vehicles. The vehicles in question will be unable to be exported again or converted for domestic sale.

III. Customs Requirements: 1. Documents must match the goods; 2. Export documents: contract, export invoice, packing list, declaration elements, export license, domestic used car sales invoice, vehicle registration information, and other registration and deregistration documents. (If transported as dangerous goods, an MSDS, transport appraisal report, UN38.3 test report, etc., are also required.) 3. Common HS codes.

IV. Shipping Company Requirements 1. Ro-Ro Ships: Special Provision 961, vehicle sea transport is exempt.

Container ships: Class 9 dangerous goods

UN3166 Vehicles powered by flammable gas fuel cells or flammable liquid fuel cells; UN3171 Battery-powered vehicles (banned from January 1, 2026); UN3556 Vehicles powered by lithium-ion battery packs; UN3557 Vehicles powered by lithium metal battery packs; UN3558 Vehicles powered by sodium-ion battery packs.

2 cases of violations

In July 2024, Sichuan company A entrusted Shanghai agent B to declare a batch of 6 electric vehicles to customs under general trade, with a value of RMB 650,000.

After the goods were released, the company discovered an error in the declared product name and product number. The actual products were 6 used Nezha brand 120kW pure electric minibuses, product number 8703800010. An export license is required for export, but the company failed to submit one.

Following the incident, the company promptly obtained the necessary export license. A fine of RMB 19,700 was imposed. Note: Product names must be declared accurately; it is recommended to use “used + brand + displacement/power + vehicle type”.

Company: The goods are listed in the controlled goods catalog. Export licenses were not submitted during customs declaration. If the exporter later obtains the licenses retroactively, does this still constitute “unlicensed export”? Customs: This behavior constitutes “unlicensed export”.

According to the Customs Law of the People’s Republic of China and the Regulations on the Administration of Declaration of Import and Export Goods by the Customs of the People’s Republic of China, licenses must be submitted during declaration. Therefore, if the exporter fails to obtain the export license for that batch of goods at the time of declaration, or submits the export license for other batches of goods, it constitutes “unlicensed export”.

Submitting an export license application before customs declaration and obtaining the export license for that specific batch of goods after customs declaration does not affect the nature of “unlicensed export”.

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