China New-Vehicle Export Rules Are Changing: Complete Your Purchase and Shipping Formalities Before 31 December
A new annual export-licence cycle starts on 1 January 2027, with higher thresholds and some rules still unpublished. This page tells you what to do now.
Last updated: 6 November 2026 | Scope: new and near-new vehicle exports
⚠Notice: this article covers only changes to NEW-VEHICLE export rules. Regular used-car export continues under existing rules and is unaffected by what is described here.
31 DecYour window under the current rules
15 DecTarget date for completed formalities (our safe-landing line)
2027 cycleHigher thresholds, details still pending
13% → 9%NEV VAT rebate cut from 1 Apr 2027 — ~US$3k less per vehicle
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To the 15 Dec safe-landing line
Get your order into this year's last shipping window
15 December is the 'safe-landing line' we set for you: year-end capacity is stretched, and the buffer exists to make sure your vehicles ship on time. For each order, the date is confirmed together.
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The short answer
Read these four lines first. Everything below explains them.
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A rule on paper does not mean the paperwork can actually be completed. Take the zero-km route (registered for less than 180 days): the rules require a manufacturer-stamped After-sales Service Confirmation Letter, and manufacturers issue such letters only in very rare cases, making this route very difficult to complete in practice. We therefore do not treat it as a core 2027 backup and strongly advise prioritising the proven, more stable authorised-export or 180-day routes — keeping certainty for your order.
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From 1 January 2027 a new annual export-licence cycle begins: modified-vehicle routes add a manufacturer-stamped document requirement, and the same type of requirement is very difficult to satisfy in practice. Separate 2027 rules for the zero-km and 180-day routes have not yet been published.
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The only window you can count on is before 31 December. We recommend collecting orders from your own buyers early, locking vehicles and prices, and having all formalities completed and the vehicles ready to ship by 15 December.
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The later you wait, the less certain the cost and delivery: from 1 April 2027 the VAT export rebate for new energy vehicles falls from 13% to 9%.
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First, the four export routes
There is more than one way to export a new car. See the four routes first, then how things stand now and how they change next year.
⚠The four routes above are all new-vehicle export routes (including the approach of first registering a new car in China and then exporting it under the 0-km / 180-day rule). Regular used-car export follows a separate set of rules and is outside the scope of these changes.
Main route now · finish before year-end
Authorised export
How it works
The vehicle manufacturer obtains annual export eligibility and applies for an export licence per shipment. Commonly used for Chinese domestic brands.
2027 status
The most reliable route today. The 2027 annual filing adds overseas service-network evidence and a price-compliance commitment for exporting companies, so there are more steps and delivery needs extra buffer. We recommend scheduling this year's volume before 31 December.
Higher 2027 bar · do not bet on it
Modified-vehicle export
How it works
A qualified converter performs a light conversion on a new car and the vehicle is exported as modified. Commonly used for joint-venture brands.
2027 status
From the 2027 cycle, specific cases — simple conversions such as tool, patrol or training vehicles used to apply for passenger-car export eligibility — require a Shared After-sales Service Confirmation Letter stamped by the original vehicle manufacturer. Manufacturers issue such stamped documents only in very rare cases and obtaining them in practice is very difficult, so whether this can be delivered in 2027 is highly uncertain. Do not build your order on this route.
High barrier · not a core option
Zero-km (registered under 180 days)
How it works
A new car is registered in China and exported as a used car within 180 days of registration.
2027 status
It requires the vehicle manufacturer's stamped After-sales Service Confirmation Letter; without it no licence is issued. Manufacturers issue such letters only in very rare cases and completing the route in practice is very difficult. The rule exists on paper but is very hard to carry out. We therefore do not treat it as a core 2027 backup and strongly advise prioritising the proven, more stable authorised-export or 180-day routes.
Workable · plan six months ahead
180-day used-car route
How it works
A car registered for more than 180 days is exported as a used car in the normal way.
2027 status
No manufacturer letter is required, so this is a genuinely workable alternative under the current rules — but registration and the 180-day holding period must be planned ahead, with capital and inventory costs taken into account. Separate 2027 rules have not been published.
Two clarifications
Export eligibility is filed per company and per calendar year, once a year. A company that misses the filing, or fails to correct it during the public-notice period, will not have its licence applications accepted. The September–October filing window each year therefore directly affects the processing rhythm of the following year.
Since 1 Jan 2026, battery-electric passenger cars (HS 8703801090 for reference) have also been subject to export licence management.
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Where things stand now · 2026, before 31 December
Exports are proceeding normally under the current rules. Here is the status of each of the four routes.
Authorised export: proceeding normally; this is the main route today.
Modified-vehicle export: proceeding normally, with the current requirements for proof of genuine conversion, MIIT catalogue listing and valid CCC certification.
Zero-km (registered under 180 days): the rules require the manufacturer's After-sales Service Confirmation Letter, and manufacturers issue such letters only in very rare cases and completing the route is very difficult in practice. We therefore do not treat it as a core 2027 backup and strongly advise prioritising the proven, more stable authorised-export or 180-day routes.
180-day used-car route: no manufacturer letter is required once 180 days have passed, so it can proceed normally — but registration and the holding period must be planned ahead, with capital and inventory costs taken into account.
So before 31 December the window you can actually plan and produce against is right in front of you: collect orders early, lock vehicles and prices, and finish the formalities by 15 December.
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What changes next year · 2027, after 1 January
A new annual export-licence cycle begins with higher thresholds; separate 2027 rules for the zero-km and 180-day routes have not been published.
Overseas service networks must be verifiable: agency contracts, local licences, repair-capability records — an export-side filing requirement.
Shared After-sales Service Confirmation Letter: in specific conversion cases, issued and stamped by the original vehicle manufacturer.
Overseas Compliance Commitment: price compliance and accurate declared prices when applying for export licences.
The conclusion is simple: the 2027 thresholds are higher, the parts requiring a manufacturer stamp are very difficult to satisfy, and the separate 2027 rules for the zero-km and 180-day routes have not been published. The only window you can count on is to complete the order under the current process before 31 December.
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Questions & Answers
Split by timeframe: first, what to do with this order before 31 December; second, what happens after 1 January 2027. Click to expand.
1 · Before 31 December — get this order done
Q1.1Why must we decide before 31 December?
Because a new annual export-licence cycle starts on 1 January: modified-vehicle routes add a manufacturer-stamped document requirement, and the 2027 rules for the zero-km and 180-day routes have not been published. Order now and your shipment follows the current, proven process. After that node, you would be waiting for new-cycle rules and processing rhythms to become clear. We do not recommend building your order on unpublished details.
Q1.2What is the last date to order and pay?
Treat 15 December as the target for 'all formalities completed and vehicles ready to ship' — not as the ordering date. Order confirmation, payment arrival, vehicle preparation, licence application, customs declaration and vessel booking all take time and all get congested in December. Ordering and payment must happen earlier; the date for your order is the one confirmed in our direct discussion. Do not plan around 31 December.
Q1.3What does 'collect orders early and lock the vehicles' actually involve?
First confirm the model, specification, quantity and delivery batches in writing. We then lock the vehicle source and price against your order and work backwards through payment arrival, formalities, customs declaration and vessel booking. Vehicle supply and shipping space are tight at year-end — early confirmation gets early production slots.
Q1.4If formalities are not finished by 15 December, can nothing ship?
It is not a hard official deadline — it is the buffer we recommend. After that date, production slots, FX settlement, licensing and vessel space all queue up, and the closer to year-end the harder it is to clear the node. Whether and until when your order can proceed is confirmed in our direct discussion with you.
Q1.5How long can the price be held?
We state the quote validity in the order. Vehicle supply and freight rates move at year-end, and the NEV rebate falls from 1 April 2027, so the later you lock, the less controllable your cost. Lock the order and the price first, then schedule later batches.
2 · After 1 January 2027 — watch the rules before planning volume
Q2.1What changes for modified-vehicle export from 1 January 2027?
There are several routes for exporting new cars; modification is only one of them, and the others continue as normal. For modified-vehicle export specifically, from the 2027 annual cycle: the exporting company must hold eligibility for that year; in specific cases — simple conversions such as tool, patrol or training vehicles used to apply for passenger-car export eligibility — a Shared After-sales Service Confirmation Letter stamped by the original vehicle manufacturer is newly required; and the filing adds overseas service-network and price-compliance requirements. Manufacturers issue such stamped documents only in very rare cases, so completing them in practice is very difficult. We therefore do not recommend building your 2027 volume on modified-vehicle export. Separate 2027 rules for the zero-km and 180-day routes have not been published; we will keep following them and keep you updated.
Q2.2Will the zero-km and 180-day routes still work in 2027?
The current rule is MOFCOM Notice 648 / 2025: vehicles registered for less than 180 days need the manufacturer's After-sales Service Confirmation Letter, without which no licence is issued; vehicles past 180 days do not need that letter, but registration and holding time must be planned in advance. Manufacturers issue such letters only in very rare cases, so completing this route in practice is very difficult. As of 6 November 2026 no separate 2027 rule has been issued, and the current rule has no expiry date. We will keep following it and keep you updated.
Q2.3When will the 2027 details be clear? Do we need to track policy ourselves?
No. Separate 2027 rules for the zero-km and 180-day routes have not been published, and the processing rhythm of the new cycle will depend on actual implementation. As soon as official rules are updated we will tell you first, including what they mean for your orders.
Q2.4How will costs change in 2027?
MOF and STA Announcement No. 29 of 2026: from 1 April 2027 the VAT export rebate rate for new energy vehicles falls from 13% to 9%, determined by the export date on the goods declaration, with applicable models following the HS codes in the attached product list. A smaller rebate means higher export cost and less room on the quote. This does not restrict exports, but it does affect price.
Five things to confirm with us now
No need to study the regulations yourself. Confirm these five and we schedule the formalities.
01Confirm model, specification, colour and quantity in one go.
02How many units in this batch, how many shipments, and your target arrival date?
03On which dates will the order be confirmed and the payment arrive?
04Until when is this quote locked, and how will later batches be priced?
05Do our paperwork-completion date and expected shipping date match the delivery you promised your own buyers?
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Timeline: from now to April 2027
The two orange markers are the key dates we set for your order; 31 December is the last node of the current-year purchasing window.
2025-11-11Notice 648 / 2025: 180-day rule and manufacturer letter
2026-01-01180-day rule and BEV passenger-car licensing take effect
Why 15 December is our target for completed formalities
Not a rule — buffer to clear the 31 December node safely.
15 December is the 'safe-landing line' we set for you: at year-end, customs, shipping lines and licence review are all at full capacity, so this two-week buffer exists to make sure your vehicles ship on time rather than getting stuck at the port waiting for the 2027 rules. For each order, the final date is the one we confirm together.
Before a new annual licence cycle starts, orders cluster and four steps slow down at once:
STEP 01
Vehicle supply / conversion slots
Year-end orders fill vehicle supply and production slots.
STEP 02
Payment & FX
Payment arrival, booking and FX settlement need working days and bank cut-offs.
STEP 03
Export licence
Every vehicle needs its own licence; December applications cluster and any correction costs another round.
STEP 04
Logistics
Customs declaration, inland transport and vessel space all tighten before year-end.
So 15 December means 'all formalities completed and vehicles ready to ship' — not the ordering date. Order confirmation and payment arrival must happen earlier. That buffer keeps your order out of the 2027 cycle. The date for your order is the one confirmed in our direct discussion.
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Cost note: NEV export rebate falls from 1 April 2027
This does not restrict exports — but the later you buy, the less controllable the cost.
MOF and STA Announcement No. 29 of 2026 (12 Oct 2026): from 1 April 2027 the VAT export rebate rate for new energy vehicles falls from 13% to 9%.
13%9%-4 pp
Do the maths: on a single NEV with a rebate of about US$10,000, after the rate drops from 13% to 9% on 1 April, that vehicle loses about US$3,000 in rebate — straight off your margin.
A 4-point rate cut means less VAT refunded to the exporter — in other words, higher export cost and less room on the quote.
Effective date and scope: determined by the export date stated on the goods declaration; applicable models follow the HS codes in the attached NEV Product List. It does not automatically apply to every vehicle.
For products subject to consumption tax, the export consumption tax refund / exemption policy is unchanged.
Declarations completed before 31 March 2027 are assessed at the old rate; the declaration date and official implementation govern.
Your move: if this batch completes formalities and ships before 31 December, it is locked under the current cost basis. Build the rebate cut into NEV orders from Q2 2027; state quote validity and cost-adjustment clauses in the contract; check pricing per model and per customs code.
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Guidance for our overseas B2B partners, split by timeframe
For importers, distributors and fleet buyers — what to do now, and what to wait for next year.
A · Now to 31 December: get the order done
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Collect orders early and lock downstream demand
Start taking orders and deposits from your own buyers now and fix the volume for the December batch. Vehicle supply, production lines and vessel space are allocated in sequence at year-end; one step later means January or beyond.
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Lock vehicles and price before the details
Once model, specification and quantity are confirmed, let us lock the vehicle source and the quote. Prices move at year-end — locking first is cheaper than negotiating while you wait.
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Move the payment-arrival date forward
Payment, booking and FX settlement need working days and bank cut-offs. Bring payment arrival into early December so there is still room for corrections and extra units.
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Work backwards from 15 December
Start at 'formalities complete and ready to ship' and schedule backwards: order, payment, documents, licence, customs, vessel booking. Keep a buffer at every step and let nothing fall into the last week of December.
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Settle the shipping plan in one discussion
Check customs declaration, vessel booking, destination ETA and the promise to your own buyers together, so the shipment is not stuck on space after the paperwork is done.
B · After 1 January 2027: check the rules before planning volume
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Do not build 2027 volume on unpublished details
Separate 2027 rules for the zero-km and 180-day routes are not out, and the manufacturer-stamped document newly required for conversions is very difficult to obtain. Plan volume on the proven authorised-export route first and adjust once the rules are clear.
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Let us update you — no need to track policy
As soon as official rules change we will tell you first, including what it means for your orders. Just keep the communication channel with us open.
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Write post-1-April cost variables into the contract
The NEV export rebate falls 13%→9% on 1 Apr 2027 (by declaration date). State quote validity, cost adjustment, FX and freight terms for 2027 up front so a price change never becomes a last-minute dispute.
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Five things to do now
Do these in order and clear this batch before 31 December.
Confirm model, specification, colour and quantity in writing.
Confirm the shipment schedule for this batch and the target arrival date.
Put the order confirmation and payment arrival in early December.
Confirm the quote validity, paperwork-completion date and expected shipping date with us.
Complete the formalities by 15 December as agreed — do not wait for the last week of December.
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Important notice
This article is a commercial reminder for our customers, not legal advice and not an official interpretation of Chinese regulations. Export licences are handled by authorised exporting companies holding eligibility; the final authorities are officially published rules, the list of eligible companies and the export licence actually issued, together with MOF / STA announcements and the export date on the goods declaration. We set 15 December as your 'safe-landing line' to avoid the year-end congestion across customs, shipping lines and licence review and to ensure your vehicles ship on time — it is not a government deadline, and the final date is the one we confirm together. We will revise this page and inform you as soon as official rules are updated.