The short answer: from 1 January 2026, China applies export-licence administration to the specified pure-electric passenger vehicles described in MOFCOM Announcement No. 54 of 2025, with reference customs code 8703801090. This is not the same as IMDG acceptance or permission to register the vehicle in the destination country.
Three independent gates
| Gate | Responsible decision | What it does not prove |
|---|---|---|
| China export licence | Eligible exporter and licence process under Chinese rules | Carrier acceptance or destination registration |
| Transport acceptance | Correct vehicle/battery classification, condition, documents and stowage for the selected mode | Roadworthiness or market approval after arrival |
| Destination approval | Homologation, safety, conformity, import and registration requirements in the buyer's market | That the Chinese exporter is licensed |
Do not release payment or move vehicles to port until all three gates have named owners.
1. Confirm whether the 2026 licence rule applies
MOFCOM, MIIT, GACC and SAMR announced export-licence administration for “other passenger vehicles equipped only with a drive motor and having a vehicle identification code,” with reference customs code 8703801090, effective 1 January 2026. MOFCOM Announcement No. 54 of 2025
For each shipment, confirm:
- new or used vehicle status;
- vehicle type and intended customs classification;
- VIN and model;
- exporter named on the declaration;
- manufacturer's and exporter's eligibility;
- export licence number and validity;
- consistency across contract, invoice, vehicle certificate and customs data.
The official 2026 application notice describes the online process and reiterates that planned exporters of the covered pure-electric passenger vehicles must apply as required. MOFCOM 2026 application notice
2. Freeze a VIN-level commercial file
Create a master vehicle list before transport:
- VIN;
- manufacturer, brand and model;
- production date and condition;
- battery chemistry, model and rated energy;
- colour and configuration;
- unit value and Incoterm;
- export certificate/licence references;
- destination-market approval reference;
- keys, accessories and spare parts;
- photographs of VIN, nameplate, exterior and odometer where applicable.
Any change after booking should trigger document revalidation.
3. Prepare transport acceptance
The 2024 IMDG Code edition including Amendment 42-24 is mandatory from 1 January 2026. Vehicle classification depends on battery technology, condition and how the vehicle is presented for transport. IMO IMDG Code
Before requesting Ro-Ro, container or rail space, send the carrier:
- vehicle model and VIN quantity;
- battery type and transport classification;
- UN 38.3 evidence for the battery type where applicable;
- SDS or safety information requested by the carrier;
- vehicle condition and state-of-charge information where required;
- dimensions, weight and ground clearance;
- leak, alarm, immobilisation and key-control status;
- destination and transshipment route.
Used, damaged, defective, accident-involved or recalled vehicles require separate disclosure and may not be accepted on a standard service.
4. Choose Ro-Ro or container by the shipment
| Factor | Ro-Ro | Container |
|---|---|---|
| Typical fit | Operational vehicles on a supported port pair | Small lots, special routing or added physical enclosure |
| Handling | Port driving, key control and vehicle condition report | Loading geometry, blocking/bracing and container weight distribution |
| Main risk | Port acceptance, sailing schedule and vehicle access | Improper securing, tight clearances and hidden damage |
| Evidence | VIN list, condition photos, acceptance and handover record | VIN list, loading plan, securing photos, container and seal record |
For either mode, obtain written carrier acceptance for the actual model and condition.
5. Destination-country gate
Ask the importer or homologation adviser to confirm before purchase:
- whether the model may be imported and registered;
- required safety and conformity approvals;
- steering side, lighting, charging interface and language rules;
- battery or environmental requirements;
- age or condition restrictions for used vehicles;
- duties, taxes and valuation;
- after-sales, recall and spare-parts obligations.
A vehicle that can leave China may still be commercially unusable at destination.
Release checklist
What to send DDNZ
Send the VIN/model list, new/used status, exporter, reference HS code, licence status, battery data, dimensions, origin, destination and preferred mode. DDNZ can prepare a gate-by-gate document checklist and request carrier acceptance. Final export, DG and destination approvals remain with the responsible licensed parties.