On November 11, 2025, the Ministry of Commerce, the Ministry of Industry and Information Technology, the Ministry of Public Security, and the General Administration of Customs jointly issued the “Notice on Further Strengthening the Management of Used Car Exports,” which directly addresses the industry’s unspoken rule—the chaos of “zero-kilometer used cars.”
The new regulations stipulate that, starting January 1, 2026, for vehicles applying for export that are less than 180 days (inclusive) from their registration date, an “After-Sales Service Confirmation” issued by the vehicle manufacturer is required; otherwise, an export license will not be issued.
This policy is widely seen as the end of the era of rapid, unregulated growth in the “zero-kilometer used car” market.
The tricks of “zero-kilometer used cars”
The concept of “zero-kilometer used cars” entered the public eye following public criticism by Wei Jianjun, chairman of Great Wall Motors.
“There’s a strange phenomenon now called ‘zero-kilometer used cars,’ meaning they’re registered as soon as they get license plates, seemingly sold, but actually end up back in the hands of used car dealers.
There are three or four thousand dealers selling them; it’s very chaotic,” Wei Jianjun pointed out. These vehicles essentially refer to “nearly new” cars that have been registered but have less than a few dozen kilometers on the odometer and have been virtually unused.
In the 2024 used car market, vehicles “registered for ≤3 months and with ≤50 kilometers” accounted for as much as 12.7%, meaning that one in every eight used cars was a nearly new car that had just been registered and then resold.
Data shows that my country’s used car exports were only 4,300 units in 2020, but exceeded 436,000 units in 2024, covering more than 160 countries and regions. From January to July 2025 alone, my country’s exports of new energy passenger vehicles reached 1.199 million units, a year-on-year increase of 57.1%. Industry insiders predict that perhaps 30% of these are “zero-kilometer used cars.”
Behind this surge in such vehicles lies a mature arbitrage industry chain. Some companies have discovered that they can circumvent some export restrictions by registering vehicles domestically and exporting them immediately, thus creating the so-called zero-kilometer used car market.
This gray area has bred unregulated operations. An industry veteran revealed, “Some companies simply add a toolbox or change the nameplate to the vehicle and declare it as a modified vehicle for export, but there are no corresponding after-sales service centers overseas.”
Some automakers and dealers exploit policy loopholes by registering new cars as used cars for export, circumventing regulatory requirements and tariff differences for new car exports.
Automakers can use this to boost sales, obtain subsidies, and clear inventory; dealers can lock in rebates based on registration volume; and used car dealers can acquire vehicles at low cost and then profit from the price difference through cross-border channels. Although these vehicles are nominally used, they are essentially new cars, lack official manufacturer warranties, and may pose risks related to ownership and debt, damaging the brand image of legitimate businesses.
In the domestic market, the low prices of zero-kilometer used cars directly disrupt the normal pricing system. A new energy vehicle with an official price of 130,000 yuan may sell for only 80,000-90,000 yuan as a zero-kilometer used car, a price reduction of over 20%.
This abnormal pricing impacts the sale of new cars through legitimate channels. In overseas markets, these exported vehicles are not adapted for local conditions; their language systems, charging interfaces, map navigation, and even after-sales service systems are incompatible with local standards, resulting in poor user experience and difficulties in obtaining after-sales complaints.
According to market tracking data, the three-year residual value rate of Chinese “zero-kilometer used cars” exported to Russia is only 28%, while that of Japanese cars is generally over 50%.
This huge gap easily leads overseas customers to solidify the stereotype of Chinese cars as “low-price and low-quality,” affecting Chinese automakers that are genuinely trying to pursue a value-driven approach.
More seriously, this behavior distorts the true industry data.
Some automakers use this method to inflate sales figures, amplifying market supply and demand, interfering with policymakers’ judgment of the industry’s true performance, and increasing the risk of policy misjudgment.
In the 1990s, Chinese motorcycles rapidly seized the Southeast Asian and African markets with a low-price strategy, but due to a lack of unified standards and after-sales service systems, they ultimately lost overseas markets due to a reputation for “low price and low quality.”
This profound lesson serves as a warning for China’s new energy vehicle exports—disorderly expansion without quality control will ultimately erode long-term competitiveness.
Long-term impact of the new policy
We predict that the new regulations jointly issued by the four departments will lead to a reshuffling of the export industry.
Some companies that engage in export arbitrage under the guise of “zero-kilometer used cars” will be forced to transform or exit the market. Automakers will take full control of export business, managing the entire chain from product development and localization to after-sales service, which will help build a high-end image for “Made in China 2025.” One of the core elements of the new policy is the “180-day registration period + after-sales confirmation letter.”
The new policy stipulates that from January 1, 2026, for vehicles applying for export that are less than 180 days old from the registration date, exporting companies must provide an after-sales service confirmation letter from the OEM—including the country of export, vehicle information, and information on after-sales service outlets, stamped with the OEM’s authorized seal. This aims to guide exporting companies to work with automakers and overseas importers to ensure after-sales service, guaranteeing the supply of repair parts and technical support.
Undoubtedly, this is to curb speculative behavior of “new cars becoming used cars”—automakers, to maintain their brand and overseas presence, typically do not issue such certificates for vehicles from gray market channels.
Without certification, vehicles cannot be exported. This requirement directly links “after-sales responsibility” with “export qualification,” pushing companies towards a long-term mindset of “full lifecycle service.”
It also encourages export companies to collaborate with supply chain partners such as logistics, finance, and third-party quality assurance agencies to provide “one-stop” services for used car export preparation, inspection, customs clearance, and logistics.
The notice also establishes a dynamic management and exit mechanism for enterprises. It requires local commerce departments to strengthen the construction of a credit evaluation system for used car exports and to conduct daily supervision and dynamic management of enterprises in accordance with the “Negative List of Dishonest Behaviors in Used Car Exports.”
The negative list precisely identifies seven major violations, including “exporting prohibited vehicles,” “forging motor vehicle registration certificates/after-sales service confirmation letters,” and “failing to fulfill quality assurance and after-sales responsibilities.”
Some industry insiders point out that for export companies that have already accepted overseas orders, the new regulations may lead to fulfillment difficulties: “If many overseas customers have a delivery cycle of up to 180 days (6 months) for new cars, and if customers placed orders before the new regulations took effect, delivery may occur after the new regulations take effect, potentially causing many export companies to delay fulfillment or even be unable to fulfill their orders.”
Previously, the “zero-kilometer used car” channel also served a market expansion function in regions not covered by automakers’ overseas business.
Under the current price war, some participating companies are essentially earning tax rebates and subsidies. However, after the new regulations are introduced, only a few leading used car exporters may survive.
In the long run, the new policy will promote the standardization, normalization, and branding of the used car export industry, guiding the industry to focus on exporting “genuine used cars,” shifting the focus from pursuing export quantity to improving quality and service, perfecting the vehicle condition inspection and evaluation system, and truthfully disclosing vehicle conditions to overseas users. This includes supporting enterprises to use trade promotion platforms to explore diversified markets, encouraging the establishment of integrated service outlets for “display, transaction, warehousing, and logistics” in key markets, and promoting and improving the supply chain support for automobile manufacturers, logistics institutions, financial institutions, and third-party quality assurance institutions. This will reduce overseas operating costs, enhance consumer trust, and drive the industry’s transformation into a “product + service + ecosystem” model, enabling it to achieve steady and sustainable growth in the international market.
How should foreign trade export enterprises respond?
In response to the new policies, car dealers need to proactively adjust their business strategies:
This new policy establishes a “triple regulatory” system to standardize export order from the source.
First, stricter qualification supervision.
Starting in 2026, the export of new energy vehicles requires authorization from the automaker, and there will only be one long-term export registration opportunity per year. Applications must be reviewed by the provincial commerce commission or department and then submitted to the Ministry of Commerce and other ministries for joint approval.
Second, transparent process supervision. The new regulations emphasize the need to provide clear written materials and actual evidence of modifications, comparisons, modification qualification verification, and after-sales service guarantees.
Third, clear responsibility supervision. After-sales service responsibility is explicitly assigned to the OEMs, requiring them to be responsible for the subsequent maintenance of exported vehicles.
While implementing strict regulations, the policy also emphasizes three guiding principles: guiding companies to focus on genuine used car business and seek customers who can guarantee sales; guiding the industry to shift from price competition to value competition; and guiding the establishment of a complete overseas service network, proposing suggestions for jointly establishing repair stations or service networks.
After the implementation of the new policy, China’s automobile exports will mainly rely on three formal channels—new cars, compliant modified vehicles, and genuine used cars.
At the same time, the overseas expansion of electric vehicle charging and energy storage facilities, as well as the overseas expansion of automotive aftermarket repair services, will become important supports for enhancing the global competitiveness of Chinese automobiles.
The industry needs to pay special attention to three key deadlines: Applications must be completed before October 26, 2025; authorization from modification plants or original equipment manufacturers (OEMs) must be obtained before January 1, 2026; applications submitted after January 1, 2026 will face a 180-day review period, and the Ministry of Industry and Information Technology (MIIT) is highly likely to reject them. The lack of unified global certification standards is a major technical barrier for Chinese cars going global.
EU certification is the basic certification globally, except for the US, but different markets have their own requirements: Ethiopia requires COC certification, while Russia requires OTC certification, and after August 31 this year, all tests must be conducted in Russia.
The Russian market has set even stricter implicit barriers for Chinese cars, with a pass rate not allowed to exceed 30%, and has explicitly prohibited four car companies from entering its market.
Industry insiders point out that domestic 3C standards are not mutually recognized overseas, posing a significant challenge to the export of modified vehicles.
Modification plants wishing to export to other countries must register with the relevant country’s Ministry of Commerce and have sales and cooperative outlets. Overcoming certification barriers requires a systemic approach.
Experts recommend adopting a “production-to-order” model, finding matching vehicle sources and modification shops, carrying out modifications at minimal cost and obtaining authorization, and finally confirming the testing and certification agency to complete the tests and obtain the necessary certificates.
The new policy will trigger a profound restructuring of the automobile export industry. On the one hand, companies with poor business practices, incomplete or incorrect application materials will be eliminated;
on the other hand, strong and compliant companies will gain greater room for development. “The new policy benefits some strong companies, while for others it may be a short-term challenge, but it could drive them to explore export markets for high-value products,” an industry expert analyzed. The future industry landscape will show two major trends of concentration: new car resources will be more concentrated in the hands of a few large companies;
the modified car market will gravitate towards qualified and large-scale enterprises.
For companies unable to obtain brand authorization, they can turn to exporting genuine used cars; however, modified cars must meet three conditions: certification, announcement, and genuine modification, and the modification category must correspond to the Ministry of Industry and Information Technology’s catalog.
The new policy marks a strategic shift in China’s auto exports from “trade-oriented overseas expansion” to “systematic overseas expansion.”
The Ministry of Commerce added two new requirements: first, manufacturers must achieve economies of scale; second, regulatory departments must collaborate, emphasizing information sharing.
The policy released at the end of September also clarified the requirement for formal announcements and added 3C certification requirements. This shift necessitates companies redefining their roles.
Traders need to transform into service providers, establishing closer partnerships with OEMs; aftermarket modification shops must accurately position themselves and avoid excessive competition; all participants should plan for the long term and jointly enhance the global image of Chinese auto brands.
“Chinese brand automakers should not lower their product prices when going global,” industry experts emphasized. EU certification is only a basic requirement; more importantly, a complete overseas service system is crucial.
China’s auto exports have reached a point where the bar is raised. The exit of zero-kilometer used cars is not the end but a new beginning. From going it alone to going global as a group, the Chinese auto industry is learning how to go further in the international market. (End of text)
