China Document 648 2026: How Used Truck Buyers Should Vet Chinese Suppliers
If you buy used trucks from China, the most important Chinese regulation of 2026 is not a tariff. It is Document 648 - the Notice on Further Strengthening Used Vehicle Export Administration (Shangmao Han [2025] No. 648), issued on November 11, 2025 by the Ministry of Commerce, the Ministry of Industry and Information Technology, the Ministry of Public Security and the General Administration of Customs, and effective from January 1, 2026. It decides which Chinese exporters stay in business, and smart buyers are already using it as a supplier screening tool.
What Document 648 Changes for Exporters
The notice tightens four areas at once:
- New-vehicle-as-used control: trucks registered less than 180 days can only be exported with an After-sales Service Confirmation issued by the vehicle manufacturer itself - and the interpretation by the China Automobile Dealers Association stresses it must be the OEM listed in the MIIT announcement, not a group sales company, an affiliate or a conversion plant.
- License data integrity: brand, model, registration date and transfer-for-export date on the export license must match the vehicle registration certificate exactly. Repeated misreporting leads to official notifications of both the company and the licensing office.
- Dynamic management and exit mechanism: exporters on the dishonesty negative list face interviews and mandatory rectification; repeated offenders or firms that fail warranty and spare-parts obligations can lose access to export licenses - including related persons who set up new companies to dodge the rules.
- Modified-vehicle scrutiny: conversion exporters must prove the conversion is real with a chassis purchase agreement, before-and-after photos and matching MIIT announcement plus compulsory certification entries, otherwise no license is issued.
The Negative List: Seven Behaviors That Should End a Deal
Document 648 attaches a negative list of dishonest behaviors that buyers should treat as red flags when they appear in a supplier history: exporting prohibited vehicles, forging registration certificates or after-sales confirmation letters, failing quality-warranty and after-sales obligations, repeated license misreporting, exporting vehicles that cause major quality or safety incidents, and related-party evasion after violations. The context matters: China used vehicle exports grew from about 4,300 units in 2020 to 436,000 units in 2024 across more than 160 countries, so regulators are clearly protecting the reputation of a strategic export sector.
Four Checks Before You Wire a Deposit
- Ask for the export license copy of a recently shipped truck and check that the registration dates and vehicle data are consistent - a supplier that fills licenses sloppily for others will be sloppy with your order too.
- If a truck was registered under 180 days ago, require the manufacturer-issued After-sales Service Confirmation with destination country, vehicle details and overseas service outlets. No OEM letter, no deal.
- Test the warranty posture: Document 648 ties license access to warranty and spare-parts support, so a serious supplier can state in writing what parts, technical documentation and response times you get.
- Stack independent verification: combine Document 648 screening with a pre-shipment inspection and the T/CADCC 009-2025 remanufacturing standard, then run our own used truck inspection checklist before final payment.
How This Fits the 2026 Rule Set
Document 648 works together with the earlier batch-license reform and the 180-day confirmation rule that took effect on January 1, 2026 - the operational details are in our guide to the one-batch-one-license system. For destination-side risk, pair it with the 2026 global import rules traffic-light guide before you choose a market.
TianCheng Truck supplies certified reconditioned HOWO, Shacman, SITRAK and FAW trucks to 100+ countries with itemized FOB/CIF pricing, full export documentation and inspection support. Request a quotation - our export team replies within 24 hours.
