Over the past year China has changed its car export rules twice. The first change has applied since 1 January 2026 and concerns used cars that are in fact almost new. The second decides which manufacturers may export new cars in 2027. The news often lumps the two together, which is where the alarming headlines come from. Let's go through the documents themselves and see which parts matter to a buyer of a used car from Russia.
The 180-day rule: what has applied since 1 January 2026
The document is 商贸函〔2025〕648号, «关于进一步加强二手车出口管理工作的通知», which translates as "On further strengthening the management of used-car exports". It was signed by four agencies: the Ministry of Commerce (商务部), the Ministry of Industry and Information Technology (工信部), the Ministry of Public Security (公安部) and the General Administration of Customs (海关总署). It is dated 11.11.2025 and was published on 14.11.2025.
At its core is one rule. If 180 days or fewer have passed between the car's registration in China (注册登记) and the export application, an export licence is issued only together with a 《售后维修服务确认书》, an "after-sales service and repair confirmation" from the manufacturer. The confirmation states the destination country, the car's details and the service points in that country, and it carries the manufacturer's seal. Without it, the licence is refused.
The document also requires the following:
- the make, model and registration date in the application must match the vehicle registration certificate (《机动车登记证书》), and any mismatch means refusal;
- a negative list is introduced: forging the registration certificate, the deregistration certificate (《机动车注销证明》) or the manufacturer's confirmation itself, «二次转让待出口» (reselling a car that has already been registered for export), giving false information about a car's condition, and evading supervision;
- an offender is refused licences, and so are companies linked to it.
What the rule is aimed at
The rule targets «零公里二手车», "zero-mileage used cars". The scheme works like this: a new car is registered in China, deregistered soon after and exported as used, bypassing the manufacturer's official channels. The Ministry of Commerce stated the aim directly: «二手车与新车出口分类管理», that is, managing exports of new and used cars separately.
The effect shows in the statistics. In 2024 China exported about 436 thousand used cars, and "zero-mileage" cars are part of that figure. According to the China Automobile Dealers Association (中国汽车流通协会), used-car exports in the first half of 2026 reached 325 thousand (+61 % year on year), while "zero-mileage" cars are leaving the market and cars with real mileage are taking their place.
Who the rule does not affect
An ordinary used car registered in China more than 180 days ago does not need a confirmation from the manufacturer. The general requirements still apply: the documents must match, and the car's condition may not be described falsely. But no separate paper from the manufacturer is needed for such a car. A 2022–2024 car with tens of thousands of kilometres on the clock has almost certainly passed the six-month mark long ago.
What 404号 changes for 2027
The second document, 商办贸函〔2026〕404号, «关于做好2027年度汽车和摩托车出口许可申报工作的通知», was issued by the General Office of the Ministry of Commerce (商务部办公厅). The title translates as "On applications for car and motorcycle export permits for 2027". It is dated 29.09.2026 and was published on 30.09.2026. It is not a new law but an annual campaign: manufacturers submit applications, and its outcome decides who may export new cars in 2027.
This round brings three new things:
- manufacturers must prove they have real service points abroad: contracts, a local repair licence, photos, equipment, mechanics' certificates, spare-parts logistics;
- passenger cars converted from service, patrol or training vehicles (工具车 / 巡逻车 / 教练车) may be exported only with a 《共享售后维修服务确认书》, a shared after-sales service confirmation from the original manufacturer; this closes the "special vehicle" loophole;
- a 海外合规经营承诺书 is required, a commitment to follow the rules abroad, including stating fair prices.
The application system opened on 30.09.2026. Regional authorities were due to complete their initial review by 28.10.2026, and Shenzhen closed applications on 23.10.2026. Late applications are not accepted. The document contains no list of brands. The Russian press (Kommersant, 05.10.2026) wrote about risks for brands without their own service network in Russia, above all for models made by Chinese joint ventures of global brands. These are journalists' assessments; the document itself contains no such wording.
About "hurry up before 15 November"
Some advertising urges buyers to arrange a car before 15 November, "before the new rules come into force". The date 15 November does not appear in 404号 or in any regional notice we know of. The campaign dates, 30 September and 28 October, are deadlines for manufacturers, and they have already passed. 404号 does not apply to an ordinary used car older than 180 days. The 180-day rule has applied since 1 January 2026, and November changes nothing about it. There is no need to rush because of these documents.
What to check on a car's page
- First registration date. A PILICAR car page shows the production date or the first registration date, to the month, when it is known. If 180 days or fewer will pass between registration and export clearance, a manufacturer's confirmation will be needed, or you will have to wait. If the page shows no date, ask us or your intermediary.
- Year and mileage together. A car from this year or last year with a few dozen kilometres on the clock is most likely "zero-mileage". Ask when the 180 days run out and who will issue the confirmation.
- Matching documents. The VIN, make, model and registration date in the exporter's paperwork must match the registration certificate (机动车登记证书). A mismatch will lead to a licence refusal.
- Who handles the export. A car is registered for export by one exporter, the one your intermediary works with. Reselling a car already registered for export is on the negative list.
Our conclusion
For a buyer of an ordinary used car from China, 404号 changes nothing, either now or in 2027. The 180-day rule closed the "new car disguised as used" scheme. That is the main thing to keep in mind if you are choosing a very recent car. The 2027 requirements concern manufacturers and new cars. How far they will affect supplies of particular brands will become clear once the Ministry of Commerce sums up the campaign. We are following this and will update the article.
This is an informational article, not legal advice. The rules are applied by Chinese authorities, and local practice may differ. We found no public data on how provinces check manufacturers' confirmations or whether manufacturers issue such confirmations for Russia. Before a deal, confirm the details with the exporter and your intermediary. Sources: 商贸函〔2025〕648号 (11.11.2025), 商办贸函〔2026〕404号 (29.09.2026), the Shenzhen Bureau of Commerce notice on application deadlines. Information as of 04.11.2026.