Recently, a notice posted on the official WeChat account of the General Administration of Customs of the People's Republic of China (GACC) has drawn widespread attention in the domestic lithium battery recycling industry.
On June 9, 2025, six ministries, including the Ministry of Ecology and Environment and the General Administration of Customs, jointly issued the Announcement on Regulating the Import Management of Regenerated Black Mass Materials for Lithium-Ion Batteries and Regenerated Steel Raw Materials (Announcement No. 14 of 2025), which will officially take effect on August 1, 2025. The core highlight of this new policy is the explicit permission for the import of qualified regenerated black mass materials for lithium-ion batteries, which is recognized as a groundbreaking move that provides domestic lithium-ion battery recyclers with more compliant raw material options. This policy is of milestone significance in alleviating domestic supply pressures and promoting the healthy development of the industry.
I. Policy Background and Key Content
With the rapid growth of the global electric vehicle (EV) industry, the production and sales of lithium-ion batteries have continued to rise, bringing increasing challenges in waste battery recycling. To promote the circular use of regenerated resources and build a green, low-carbon, and circular development system, China has been optimizing its import management policies for regenerated resources. The joint announcement by the six ministries is a further refinement of existing policies under this backdrop.
The main contents of the announcement include:
1. Addition of regenerated black mass materials for lithium-ion batteries to the list of permitted imported regenerated raw materials: This is the most significant adjustment in the new policy. It clarifies that qualified regenerated black mass does not fall under the category of solid waste and can be freely imported, greatly alleviating industry concerns.
2. Categories and performance requirements for regenerated steel raw materials: While this article focuses on black mass, the announcement also adjusts the classification and quality standards for regenerated steel raw materials to improve utilization efficiency and environmental benefits.
3. Clear commodity codes and performance requirements: The announcement assigns a specific customs commodity code (3824999996) to regenerated black mass materials for lithium-ion batteries and provides detailed performance indicators in an appendix, offering clear guidelines for customs supervision and corporate compliance.
4. Refined shipping, declaration, and inspection methods: The policy specifies detailed requirements for the shipping, customs declaration, and inspection processes of imported black mass to ensure standardized and traceable imports.
These revisions collectively form a more scientific and comprehensive policy framework for China's management of regenerated resource imports. In particular, the "legitimization" of regenerated black mass opens new doors for diversifying raw material sources in the domestic lithium-ion battery recycling industry.
II. Impact of the Black Mass Import Policy on the Domestic Lithium-ion Battery Recycling Industry
The implementation of this policy is undoubtedly a strong boost for the domestic lithium-ion battery recycling industry, with multifaceted and far-reaching effects:
1. Broadening Raw Material Sources and Alleviating Supply Pressure
- Expanding compliant material options: The policy clarifies that qualified regenerated black mass is not solid waste and can be freely imported, allowing domestic companies to legally procure high-quality black mass from international markets.
- Easing domestic shortages: With the explosive growth of EVs and energy storage industries, the demand for key minerals like lithium, nickel, and cobalt continues to surge. Imported black mass can help bridge the gap while domestic recycling systems mature.
- Optimizing cost structures: Introducing international competition may stabilize domestic recycling material prices, reducing production costs and enhancing profitability.
2. Enhancing Technical Capabilities and Promoting Industry Upgrades
- Driving innovation: Stricter technical requirements for imported black mass will push domestic companies to invest more in R&D, improving core recycling technologies such as pretreatment, hydrometallurgy, and pyrometallurgy.
- Encouraging industry collaboration: The policy will foster stronger technical exchanges between domestic recyclers, international suppliers, equipment manufacturers, and downstream battery material producers.
- Increasing product value: Processing high-quality imported black mass enables the production of higher-purity battery-grade nickel sulfate, cobalt sulfate, and lithium carbonate, meeting demand for premium materials.
3. Regulating Market Order and Promoting Healthy Industry Development
- Cracking down on illegal activities: Clear standards will curb illegal imports of black mass misclassified as solid waste.
- Encouraging compliance: Detailed shipping, declaration, and inspection requirements will push companies to prioritize regulatory adherence.
- Improving standards: The policy will accelerate the development of domestic testing and evaluation standards, aligning them with international benchmarks.
4. Securing Critical Resources and Strengthening Strategic Resilience
- Reducing reliance on primary ores: Diversified imports and recycling will decrease dependence on foreign mineral resources.
- Enhancing global influence: A stronger domestic recycling industry will elevate China's role in the global lithium battery recycling value chain.
III. Challenges and Outlook
While the policy offers significant benefits, challenges remain:
- Quality control and risk management: Companies must establish robust testing and risk assessment systems.
- Technical adaptability: Variability in black mass composition demands flexible processing capabilities.
- International trade friction: Increased trade volumes may trigger new disputes or barriers.
Looking ahead, the implementation of this policy will usher in a new phase for China's lithium-ion battery recycling industry. It will not only contribute to a more comprehensive lifecycle management system for lithium batteries but also support the green and sustainable development of the new energy sector, offering Chinese solutions to global battery recycling challenges.
