1. MIIT vehicle market-access qualifications – The company must itself be a specialized modification enterprise listed in the Announcement of Road Motor Vehicle Manufacturers and Products. If it only performs commissioned bodywork installation, it must obtain formal authorization and installation-filing approval from the chassis OEM, and the entrusted modifier's name must be recorded in the MIIT system.
– Each export model (chassis and complete modified bodywork assembly) must have its own separately listed model designation. Unauthorized changes to dimensions, gross vehicle weight, cargo body capacity, or wheelbase are strictly prohibited (vehicles with understated rated capacity or that have been widened or lengthened will be impounded).
2. Foreign trade and customs qualifications – Registration as a foreign trade operator,Customs registration, the electronic port system, and a complete set of import/export rights; register as a general VAT taxpayer to qualify for export tax rebates.
– Complete company registration in the Ministry of Commerce's automobile export licensing system, selecting “modified-vehicle manufacturer” as the company type. Keep photos of the factory's production equipment, modification assembly line, and inspection stations on file (the commerce authorities will conduct on-site checks of actual production capacity).
3. Compliance of chassis sourcing – Purchase only Category II chassis listed in the MIIT announcement. Obtain the chassis certificate of conformity, vehicle consistency certificate, and VAT special invoice. Each vehicle must have its own invoice, and the VINs on the invoices and certificates must match exactly.
– Exporting vehicles assembled from chassis without proper documentation or refurbished second-hand chassis is prohibited. Retain chassis purchase contracts, invoices, and inventory-in records for at least 3 years for inspection.
II. Compliance of modification production (key requirements in the 2026 crackdown on “fictitious modifications”)
Starting in 2026, the Ministry of Commerce, Ministry of Industry and Information Technology, Ministry of Public Security, and General Administration of Customs will enforce strict controls. Cosmetic relabeling or simply adding guardrails constitutes fraudulent modification and will result in the export license being denied and the vehicle being seized and returned.
1. Evidence of substantive modification (file one set for each vehicle)
– Affix the company seal to a “Special Modification Statement” specifying the modification structure, functions, technical parameters, altered parts, and applicable standards.
– Pre- and post-modification comparison photos from 4 angles (front, side, rear, chassis), clearly showing the VIN plate and superstructure; photos of key processes (welding/hydraulics/tank assembly).
– Proof of purchase for modification components: purchase contracts and VAT special invoices for hydraulic cylinders, pumps, tanks, refrigeration units, cranes, and other items; for self-manufactured bodies, retain steel plate raw material documents and flaw-detection/pressure-test reports.
– Vehicle factory inspection records: reports on brakes, lighting, side protection, hydraulic sealing, and vehicle weight.
2. Red lines for modification parameter consistency
– The announced overall dimensions, gross vehicle weight, rated payload, axle loads, and tire specifications must not be increased without authorization. Side underrun guards, rear underrun guards, and reflective markings specified in the announcement must all be installed.
– Remake the complete vehicle identification plate after modification. The model designation on the plate,VIN, and the gross vehicle weight must exactly match the MIIT announcement. Photograph and archive both the old and new nameplates.
– Hydraulic systems, tanks, and hazardous-chemical bodies must undergo third-party pressure or airtightness testing. Attach the test report for customs clearance.
3. Factory release documentation management
– Provide both the chassis OEM's certificate of conformity and the modifier's complete-vehicle certificate of conformity. Upload the electronic certificate of conformity to the MIIT system at the same time, indicating “commissioned modification” and the name of the modifying factory.
– Create a file for each vehicle: retain the chassis invoice, invoices for modification parts, inspection reports, modification photos, factory release records, and a copy of the export contract for 5 years.
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