On January 1, 2026, the export license management system for pure electric passenger vehicles will officially come into effect. Coupled with the implementation of detailed rules for the export management of used and modified vehicles previously issued by the Ministry of Commerce and other four departments, this marks a historic transformation for China’s auto export industry.
This policy adjustment, centered on “standardizing order and improving quality and upgrading,” is by no means a short-term control measure, but rather a “supply-side reform” and “value reconstruction” concerning the long-term development of the industry.
Under the new policy, who can continue to establish a foothold in overseas markets? What lies on the path to compliant exports?
The essence of the new policy: to set things right and restructure the automotive export ecosystem.
The core objective of this series of new policies is to completely end the long-standing chaos of gray-market exports of “zero-kilometer used cars” and achieve a clear separation between official new car exports and used car exports.
Since becoming the world’s largest automobile exporter in 2023, China’s export volume has continued to climb, reaching 5.859 million vehicles in 2024, with new energy vehicles accounting for over 20%.
However, behind this expansion, problems such as unauthorized entities dumping products at low prices, exporting low-quality products, and lacking after-sales service systems have frequently occurred, seriously damaging the international reputation of “Made in China.”
Against this backdrop, the new policy constructs a full-chain regulatory system through three dimensions: First, it achieves full coverage of export licenses, requiring all pure electric passenger vehicles to apply for a license before export; those without a license will be prohibited from export. Second, it strictly controls the export of used cars, stipulating that nearly new cars exported within 180 days must submit an “After-Sales Service Confirmation” issued by the OEM, which must include information on overseas after-sales service outlets and bear the original manufacturer’s official seal. Third, it regulates the export of modified vehicles, requiring the submission of six core documents, including before-and-after modification comparison materials, procurement agreements, and parameters announced by the Ministry of Industry and Information Technology, to strictly prevent “fake modifications, real exports.”
These measures essentially aim to promote the transformation of China’s automobile exports from “scale expansion” to “quality improvement,” solidifying the foundation for branded and service-oriented overseas expansion.
Key Assessment: Three Major Trends Define the Future of the Industry
(I) National will is irreversible; compliance is the only bottom line. The core purpose of the new policy is to “correct past mistakes,” safeguarding the overseas image, long-term interests, and supply chain order of the national automotive industry. Its enforcement strength and continuity are beyond doubt.
Data shows that 80% of “0-kilometer” export license resources have been concentrated in OEMs and their affiliated state-owned enterprises, and the gray channel for “0-kilometer used cars” has been completely closed.
Hoping for a looser or more lenient policy will undoubtedly lead to missed opportunities for transformation and even compliance risks.
In the future, the responsibility mechanism of “whoever exports, is responsible” will be fully implemented. Automakers will need to assume full-chain responsibility for overseas market adaptation and after-sales service guarantees, building a positive reputation cycle.
(II) A Shared Dilemma Across the Industry: Breakthroughs Yield Advantage In the initial stages of the new policy’s implementation, the industry generally faced difficulties in obtaining authorizations and smooth agent connections. This was a common challenge for the entire industry, not just a “bottleneck” for individual companies.
Internal friction and complaints are futile. Only companies that take the lead in calmly refining their strategies and establishing compliant pathways can seize the initiative in this transformation.
Sun Xiaohong, Secretary-General of the Automotive Internationalization Professional Committee of the China Chamber of Commerce for Machinery and Electronic Products, pointed out that regulating export order is key to promoting the industry’s development towards “better, newer, and higher quality,” which will create a positive interaction with the domestic market and build a high-level dual circulation.
(III) Resource Concentration at the Top, Inevitable Role Restructuring The centralization of authorized resources means that the survival space for pure traders is greatly compressed.
The future industry will see a clear differentiation of roles: either attaching themselves to the OEM brand system and becoming officially authorized supply chain partners; or cultivating the used car ecosystem and focusing on the circulation of genuine used assets; or transforming into professional service providers, offering supporting services such as inspection, preparation, and compliance consulting.
This resource restructuring will drive the industry away from the extensive “box-moving” operation and towards a high-quality development stage of value creation.
Breakthrough Path: A Breakdown of Four Compliance Directions
(I) Maintaining “0-Kilometer” New Cars: Conquering the Authorization Barrier (Difficulty: Extremely High)
This path is suitable for companies focusing on a single or a few domestic brands, and whose overseas customers have a strong demand for “official status.” The core actions need to revolve around three points:
First, brand shift: abandon the illusion of joint venture brand authorization. Export authorization controls for joint venture brands such as BBA, Toyota, and Honda are extremely strict, and even more difficult to break through under the new policy. Resources should be concentrated on domestic OEMs with overseas expansion potential, aligning with the national brand-oriented overseas expansion strategy.
Second, precise agent search: prioritize connecting with “purely private third-party” authorized agents listed by the Ministry of Commerce, such as Beijing Yingchang and Chongqing Qingchangfeng in the Changan case. Establish cooperation through legal channels such as business information platforms, industry connections, and on-site visits. These can be used as entry points as purchasing parties or regional partners.
Third, reconstructing the value logic: prove your core competitiveness to the licensor—not simply earning trade margins, but possessing stable overseas sales channels, localized promotion capabilities, or an after-sales network foundation, aligning with the OEM’s core needs for “localization adaptation and continuous service guarantee.” Risk Warning: This path has high barriers to entry and narrow channels, making profits easily squeezed by upstream suppliers. It is also highly susceptible to policy fluctuations of a single brand, requiring strong resource integration and risk resistance capabilities.
(II) Exploring Exported Modified Vehicles: A Differentiated Approach Under Compliance (Difficulty: High, Risk: Medium-High)
Suitable for companies that cannot obtain new vehicle authorization but wish to export “quasi-new vehicles,” and whose customers are not sensitive to brand names, such as those focusing on functional vehicles like pickup trucks and vans, or niche luxury modification markets.
Key actions must adhere to compliance requirements:
First, screen compliant modification partners. From the Ministry of Commerce’s list of 200 legal modification plants, prioritize manufacturers with passenger vehicle modification qualifications and flexible operations, such as Maserati.
Second, design compliant modification plans. Collaborate with modification plants to develop a minimum-cost, controllable modification plan, focusing on interior parts, exterior kits, wheels, etc., ensuring complete documentation including before-and-after photos, lists, and conformity certificates.
Finally, reposition the product, shifting the marketing focus from “original brand new vehicles” to “XX modification plant certified upgrade models,” transferring brand value from the OEM to the modification plant. Simultaneously, optimize modification plans for overseas market demands, such as developing desert tires and high-temperature resistant air conditioning components for the Middle East market. Risk Warning: The extent of policy implementation is the biggest variable. Customs will strictly verify the authenticity of modifications, and this approach may be subject to policy tightening or even suspension. It is not suitable as a long-term main strategy and should only be used as a supplementary direction.
(III) Embracing the “180-Day Cycle” of Nearly New Cars: Opportunities and Challenges Coexist (Difficulty: Medium, Opportunities: High)
This is a golden track for the next two to three years, suitable for used car resource providers and exporters focusing on high-value markets in developing countries.
Key strategic points include:
First, prioritize applying for proprietary qualifications. If business volume is stable and long-term operations are planned, applications for used car export qualifications in the current region or lower-tier cities should be initiated as soon as possible. Proprietary qualifications offer multiple advantages, including tax rebates, customer privacy protection, and operational autonomy.
Second, strengthen professional capabilities. Establish a comprehensive used car inspection, evaluation, and preparation system to ensure vehicles meet export environmental and age compliance requirements. Simultaneously, establish stable domestic vehicle acquisition channels and strictly control vehicle quality.
Third, create differentiated advantages. Against the backdrop of decreasing “zero-kilometer” vehicles, focus on service capabilities for specific models (such as classic cars, niche performance cars), specific vehicle conditions (high-quality cars), or specific destination countries to form core competitiveness. Trend Forecast: A “rush to export” peak occurred at the end of 2025, which will lead to a short-term oversupply and declining demand in overseas markets at the beginning of 2026. Enterprises need to prepare for fluctuations in business volume, reasonably control inventory costs, and avoid blindly stockpiling vehicles.
(IV) Deepening the Pure Used Car Export Market: Building a Long-Term Barrier (Difficulty: Medium, Suitable for: Resource-Based/Service-Oriented Players)
With the advancement of new policies, the true potential of the used car export market will continue to be released. Currently, China’s used car exports account for only 7% of total automobile exports, far lower than the over 30% in Japan and the United States, indicating huge potential for future growth.
Core actions need to revolve around “professionalization” and “localization”: On the one hand, establish full-process service capabilities, covering vehicle procurement, inspection and preparation, compliant declaration, customs clearance and shipping, overseas delivery, etc., and strictly improve documents such as the “After-Sales Service Confirmation Letter” in accordance with the requirements of the new policies to ensure traceability of each vehicle.
On the other hand, develop overseas localized services, cooperate with local dealers to establish repair outlets and parts warehouses, solve after-sales pain points for overseas users, and optimize the vehicle source structure for different markets, such as exporting high-performance, cost-effective used gasoline vehicles to Southeast Asia and Africa, and promoting used new energy vehicles to the European market.
A Guide for Newcomers: Start Small, Master the Niche
Entering the market during a period of great change presents both challenges and opportunities. The traditional experience of veteran players has become partially ineffective, and pragmatism is the only rule for survival for newcomers.
First, prioritize building trust. Without established case studies and credibility, avoid rushing into large overseas clients. Instead, start by providing supporting services such as vehicle sourcing and model procurement to established domestic exporters, or establish deep partnerships with qualified companies to accumulate experience and build a reputation as a partner in overseas market expansion.
Second, adhere to a “small and refined” approach. Reject the extensive model of covering all vehicle types; focus on niche markets, such as “180-day nearly new BMW X5s,” “domestic pickup truck exports,” or “used electric vehicles from a certain country,” concentrating resources to become an expert in a specific field.
Third, personally handle the entire process. Regardless of order size, participate in every step from finding vehicles, procurement, obtaining permits, customs clearance, and shipping to delivery. Accumulate practical experience, mitigate potential risks, and build relationships with core resources such as freight forwarders and customs brokers—the most valuable asset in the initial stage.
Fourth, conservatively calculate profits. Incorporate potential costs such as policy fluctuations, funding costs, exchange losses, and overseas bad debts into the accounting model. Uncertainty is high in the early stages of new policies; a conservative strategy is a safe strategy.
A New Landscape for the Industry Under Value Reconstruction
The new automobile export policy in 2026 is not the end of the industry, but a brutal “supply-side reform.”
For established players, the focus should be on securing new car authorizations or leveraging financial advantages to dominate the near-new car supply chain. For most traders, 180-day near-new cars are the foundation for survival, with modified cars serving as a supplement. For resource-based and service-oriented players, cultivating pure used car exports and obtaining their own qualifications are key to building long-term barriers to entry. For new entrants, relying on established models and focusing on niche markets is a wise choice.
The curtain has risen, and the game has changed. Those who can establish a foothold in overseas markets in the future will inevitably be those who quickly understand the rules, flexibly adjust their businesses, cultivate vertical markets, and adhere to compliance and service standards.
China’s automobile exports are transitioning from “going out” to “going in” and “going up.” Only by adapting to trends and proactively transforming can they share in the era’s dividends of global automotive industry transformation.
