On December 11, 2025, the Department of Foreign Trade of the Ministry of Commerce and the Quota and Licensing Bureau of the Ministry of Commerce issued the 'Work Guidelines on Matters Related to the Application for Export Licenses for Used Cars and Modified Cars (Enterprise Edition)' (hereinafter referred to as the 'Guidelines'), which is a supplement and improvement to the 'Notice on Further Strengthening the Export Management of Used Cars' (Shang Mao Han [2025] No. 648, hereinafter referred to as the 'Notice') jointly issued by the Ministry of Commerce and other four departments on November 14, 2025.

The 'Guidelines' provide a detailed explanation of the application for second-hand car export and modified car export, first of all, the description of second-hand car export -

1. It is emphasized that the 'After-sales Maintenance Service Confirmation' (hereinafter referred to as the 'Confirmation') should be issued by the manufacturer of the export vehicle, and the sales company, overseas sales department, overseas authorized dealers, etc. under the manufacturer cannot issue the 'Confirmation' on behalf of the company, and the modified vehicle manufacturer cannot issue the 'Confirmation'. Moreover, the manufacturer should be an automobile manufacturer listed in the 'Announcement of Road Motor Vehicle Manufacturers of the Ministry of Industry and Information Technology' (the name is the same).

2. If a license includes vehicles from different manufacturers, each manufacturer must issue a 'Confirmation'.

3. The export vehicle information (vehicle brand, model, registration date, transfer registration date to be exported, etc.) filled in by the second-hand car export enterprise should be consistent with the 'Motor Vehicle Registration Certificate'. For second-hand cars whose export license application date is less than 180 days (including 180 days) from the vehicle registration date, the 'After-sales Maintenance Service Confirmation' must be submitted.

4. The content of the 'Confirmation' shall include the export destination country, frame number (VIN code), corresponding overseas after-sales service outlet information (address, provider, etc.) of all exported vehicles, and be stamped with the official seal of the manufacturer.

5. Vehicles that have been registered for transfer before January 1, 2026 and are to be transferred for export can still apply for an export license after January 1, 2026 without submitting a 'Confirmation'. Vehicles that have signed an export contract before January 1, 2026 but have not gone through the transfer registration procedures for export need to submit a 'Confirmation Letter'.

The above conditions have basically blocked the possibility of 'zero-kilometer second-hand car export'. It is recommended that these foreign traders either choose to engage in regular long-kilometer second-hand cars, or obtain overseas export authorization from OEMs and develop maintenance outlets, or engage in automobile modification business.

To close the loopholes in the export of falsified modified vehicles, the 'Guidelines' clarify the applicable scope for exporting modified vehicles. Specifically, if a modified vehicle is exported under the name of a new vehicle, it must apply for a permit in accordance with the aforementioned new vehicle export management regulations.  

The export declaration for modified vehicles includes the following additional reporting items: selecting whether the export is by the modified vehicle manufacturing enterprise or an enterprise authorized by the modified vehicle manufacturer, and accurately filling in the export vehicle information such as chassis (or original vehicle before modification) brand, modified vehicle brand, and vehicle model. The vehicle model should be filled in according to the naming rules of product models and names on the product parameter pages in the 'Announcement of Road Motor Vehicle Manufacturers and Products' by the Ministry of Industry and Information Technology (examples provided). It should reflect the vehicle's special functions after modification, such as 'Type X Mobile Concrete Pump Vehicle' or 'Type X Truck-mounted Crane Transport Vehicle.'  

It is also emphasized that the permit must be accompanied by the following six materials:  

1. Highlight key parts before and after modification, including detailed descriptions of modified parts and related photos; comparison photos of the front, front-left, side, and rear of the vehicle before and after modification. Each vehicle model must correspond to a description of the modified parts.  

2. Photos of the vehicular (or chassis) nameplate before and after modification, and photos of the nameplate of the original vehicle (or chassis) before modification, clearly showing all the details on the nameplate. Each vehicle must upload a comparison of the nameplates (can be merged into a single file).  

3. Provide the relevant procurement agreements. This refers to procurement agreements or contracts (including invoices) signed by the modified vehicle manufacturer when purchasing export vehicle chassis (or original vehicles) and special devices. This includes procurement agreements and invoices for chassis (or original vehicles) and special devices. The quantities of purchased chassis (or original vehicles) and special devices must match the reported export quantities. Each vehicle model must upload the corresponding procurement agreements.  

4. Product parameter pages from the announcement. Refers to the product parameter pages from the Ministry of Industry and Information Technology 'Announcement of Road Motor Vehicle Manufacturers and Products' obtained by the company (must match the type of exported products). 'Product type' refers to the 'Vehicle Name' in the announcement. For example, if exporting a 'pure electric van,' the 'pure electric van' announcement must be uploaded. Each vehicle model must upload the corresponding product parameter pages.  

5. National compulsory product certification certificate. Refers to national compulsory product certification for the same or similar products (same vehicle name). Each vehicle model must upload the corresponding national compulsory certification.  

6. Certification of compliance with the export destination country's access requirements. Materials should include certification and test reports proving that the modified vehicle meets the access requirements of the export destination country. If the export destination country has no access requirements, a written declaration stamped with the company's official seal should be submitted, along with valid national compulsory product certification and test reports for the export product. Each vehicle model must upload the corresponding proof of compliance with the export destination country's requirements.

According to the 'Notice,' the license declaration system adjusted as per the notice will go live on December 15, 2025. The old system will be suspended from 17:00 on December 12 to 24:00 on December 14. However, from December 15 to December 31, 2025, when modified vehicle export companies apply for the 2025 licenses, the relevant attachments in the license schedule do not need to be submitted. The 'Brand' column should select 'Other Brand,' and the approved vehicle modification brand should be filled in manually. When companies apply for the 2026 licenses, attachments must be submitted as required.  

According to the above document, the avenue for false modifications for export is basically blocked. The policy does not prohibit non-authorized modification companies from engaging in vehicle modification, but it emphasizes that modifications must be genuine and compliant. Companies must ensure that modifications meet national standards and can provide complete modification documentation. If the authenticity of the modification cannot be proven, or if the modified vehicle products are not listed in the Ministry of Industry and Information Technology announcement or lack valid certification, export licenses will not be issued.