[SMM Analysis] New Regulations on China's Electric Passenger Vehicle Exports: Licensing System and Overseas After-Sales Capabilities Become Key Factors

Policy Text

(I) Target Entities

Export license management shall be implemented for goods classified as other motor vehicles principally designed for the transport of persons, equipped solely with an electric motor, and having a Vehicle Identification Number (VIN) (referencing Customs commodity code 8703801090).

(II) Declaration Requirements

The eligibility criteria for enterprises applying for export qualifications, the management approach, the declaration procedures, and the application for and issuance of export licenses shall be implemented in accordance with the relevant provisions of the "Notice on Further Regulating the Export Order of Automobile and Motorcycle Products" (Shang Chan Fa [2012] No. 318) jointly issued by the Ministry of Commerce, the Ministry of Industry and Information Technology, the General Administration of Customs, the former General Administration of Quality Supervision, Inspection and Quarantine, and the former Certification and Accreditation Administration of China.

(III) Customs Inspection

Customs inspection of exported pure electric passenger vehicles shall be based on the current and effective Catalog of Import and Export Commodities Subject to Compulsory Inspection.

(IV) Implementation Timeline

This announcement shall take effect officially from January 1, 2026.

In-Depth Policy Analysis

(I) Export License Management

Starting January 1, 2026, export license management will be implemented for pure electric passenger vehicles. Enterprises must apply for a license from the competent authorities; otherwise, they will be unable to export. This measure will effectively close loopholes related to unlicensed exports and regulate market order. Specifically, enterprises must meet the following conditions:

• Qualification Requirements: Enterprises must be listed in the MIIT's "Announcement of Vehicle Manufacturers and Products" and possess valid China Compulsory Certification (CCC Certification).

• Declaration Procedures: Enterprises must submit relevant materials in accordance with the provisions of the "Notice on Further Regulating the Export Order of Automobile and Motorcycle Products" (Shang Chan Fa [2012] No. 318), including basic information about the enterprise, production capacity, and quality management system.

• License Application: Enterprises must apply for an export license from the Ministry of Commerce or its authorized agencies. The license will be valid for one year and must be reapplied for upon expiration.

(II) Overseas After-Sales Service Capability

Automakers must possess overseas maintenance and service capabilities commensurate with their export volume. For example, Category I enterprises are required to have more than 50 overseas after-sales service and maintenance outlets. Enterprises must also submit an overseas service network construction plan, including but not limited to the following:

• Parts Inventory: The parts inventory rate shall not be less than 20% to ensure the supply of parts for common malfunctions.

• Service Response Time: The maintenance response time shall not exceed 48 hours to ensure users receive timely support when encountering problems.

• Service Outlet Layout: Service outlets must cover major export markets and provide 24-hour emergency rescue services.

(III) Customs Inspection

Customs inspections of exported pure electric passenger vehicles will be conducted in accordance with the currently effective Catalog of Import and Export Commodities Subject to Compulsory Inspection. Enterprises must ensure that their exported products comply with relevant standards and requirements; otherwise, they will face strict scrutiny and penalties from customs.

IV. Industry Impact

(I) Enhancing Brand Image

By standardizing export procedures and improving after-sales service capabilities, the brand image of Chinese NEVs in the international market is expected to be significantly enhanced. This will help build a healthy and sustainable export ecosystem and strengthen the competitiveness of Chinese NEVs in the global market.

(II) Promoting High-Quality Development

This policy marks a comprehensive shift in China's NEV exports from "scale expansion" to "quality first," establishing an institutional framework for the high-quality development of Chinese NEVs in overseas markets. Enterprises will place greater emphasis on product quality and after-sales services, thereby improving user experience and brand loyalty.

(III) Strengthening Corporate Responsibility

The policy reinforces the responsibility mechanism of "whoever exports is responsible," encouraging enterprises to shift from a "scale-oriented" approach to a "quality-oriented" one. Enterprises need to increase investment in technological R&D, quality management, and after-sales services to enhance their core competitiveness.

Future Outlook

(I) Technology and Service Upgrades

With the implementation of the policy, Chinese NEV automakers will face higher export standards and requirements. This will drive enterprises to increase investment in technological R&D, quality management, and after-sales services, thereby enhancing their core competitiveness. For instance, enterprises need to continuously innovate in areas such as battery technology and autonomous driving technology, while also establishing comprehensive after-sales service systems in overseas markets.

(II) Market Expansion and Cooperation

The implementation of the policy will provide strong support for the further development of Chinese NEVs in the international market. Enterprises will have opportunities to establish long-term and stable cooperative relationships with more international partners, expanding their market share. For example, collaborating with international automakers, dealers, and after-sales service providers to jointly enhance the international market influence of Chinese NEVs.

(III) Changes in the Global Market Landscape

As the competitiveness of Chinese NEVs continues to grow in the international market, the global automotive market landscape is expected to undergo significant changes. Chinese NEV enterprises will occupy a more important position in the global market, driving the global automotive industry toward electrification, intelligence, and connectivity.

The release and implementation of this policy represent a significant step toward high-quality development for China's NEV industry. By standardizing export procedures and enhancing after-sales service capabilities, Chinese NEV automakers will place greater emphasis on product quality and user experience, thereby boosting their core competitiveness. This will lay a solid foundation for the sustained growth of Chinese NEVs in the global market and propel the Chinese NEV industry to occupy a more prominent position worldwide.