Six Government Agencies Standardize Import of Recycled Materials – An Interpretation of New Regulations on Importing Recycled Black Powder and Steel for Lithium-ion Batteries

 

 

To promote the recycling of renewable resources and regulate the import management of recycled black mass and recycled steel raw materials for lithium-ion batteries, six government agencies—the Ministry of Ecology and Environment, the General Administration of Customs (GACC), the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Commerce, and the State Administration for Market Regulation—jointly issued the Announcement on Standardizing Import Regulations for Recycled Black Powder and Steel Raw Materials Used in Lithium-ion Batteries (Joint Announcement No. 14 [2025] by the Ministry of Ecology and Environment, the GACC, the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Commerce, and the State Administration for Market Regulation). This announcement, effective from August 1, 2025, repeals the previous Announcement on Regulating the Import Management of Recycled Steel Raw Materials (Announcement No. 78 [2020] by the Ministry of Ecology and Environment, the National Development and Reform Commission, the GACC, the Ministry of Commerce, and the Ministry of Industry and Information Technology). To ensure administrative counterparts and the general public fully comprehend and accurately grasp the key revisions of this announcement, the following clarifications are provided:

Performance requirements for recycled black mass raw materials used in lithium-ion batteries

 

 

Performance Requirements for Recycled Black Mass Raw Materials in Lithium-Ion Batteries

Category	Appearance Characteristics	Parameter
		Total Nickel and Cobalt Content	Iron Content	Phosphorus Content	Lithium Content	Water-Soluble Fluorine Content	Other Parameters
Recycled Black Mass Raw Materials for Lithium-Ion Batteries Containing Nickel and/or Cobalt	A black or gray-black powder material derived from lithium-ion battery waste through processes including discharge, dismantling, pyrolysis, crushing, and sorting. The material exhibits no noticeable irritating odor and is free from visible impurities.	≥25.00%	/	≤0.80%	≥3.50%	≤0.40%	1.   The product shall be free from contamination by other waste materials. For recycled black mass raw materials used in nickel/cobalt-containing lithium-ion batteries, the molar ratio of lithium to the combined nickel-cobalt-manganese content should range between 0.95-1.10. For lithium iron phosphate (LFP) battery materials, the lithium-to-phosphorus and lithium-to-iron molar ratios should both fall within 0.95-1.10. Additionally, zinc content must not exceed 0.10%, while lead, cadmium, chromium, and arsenic contents must each remain below 0.01%. 2.   The mass fraction retained on a 60-mesh sieve shall not exceed 1.0%.
Recycled black mass raw materials for lithium iron phosphate (LFP) batteries		≤1.00%	≥18.00%	≥10.00%	≥2.00%	≤0.10%

 

 

Performance requirements for recycled steel raw materials (old)

 

 

 

Old

Category	English Name	English Abbreviation	Chinese Abbreviation	Grade	Inclusions (% max)
重型再生钢铁原料	Heavy Recycled Iron and Steel Materials	HRS	Heavy Scrap	HRS101	0.8
				HRS102	0.3
中型再生钢铁原料	Medium Recycled Iron and Steel Materials	MRS	Medium Scrap	MRS201	0.8
				MRS202	0.3
小型再生钢铁原料	Small Recycled Iron and Steel Materials	LRS	Small Scrap	LRS301	0.8
				LRS302	0.3
				LRS303	0.3
破碎型再生钢铁原料	Shredded Recycled Iron and Steel Materials	SRS	Shredded Scrap	SRS401	1.0
				SRS402	1.0
				SRS403	1.0
包块型再生钢铁原料	Bundled Recycled Iron and Steel Materials	BRS	Bundled Scrap	BRS501	0.3
				BRS502	0.8
				BRS503	0.3
合金钢再生钢铁原料	Alloy Recycled Iron and Steel Materials	ARS	Alloy Steel Scrap	ARS601	0.3
				ARS602	0.3
				ARS603	0.3
铸铁再生钢铁原料	Cast Iron Recycled Materials	CRS	Cast Iron Scrap	CRS701	0.8
				CRS702	0.3

 

 

Performance requirements for recycled steel raw materials (Updated)

 

 

New

Category	Appearance Characteristics	Parameter
		Steel physical quantity	Inclusions	Other Parameters
Standard recycled steel feedstock	With dimensions ≤1500mm in length and ≤600mm in width, produced through sorting, dismantling, and shearing of retired steel products after service life expiration, along with processing remnants and tailings from steel manufacturing. The mass exceeding maximum dimensional specifications shall not exceed 5% of total mass.	≥92.0%	≤0.80%	1.   The ambient dose equivalent rate of X and gamma radiation from raw materials (including packaging) shall not exceed the local natural radiation background level by more than 0.25 μSv/h. Surface contamination limits for alpha and beta particles are as follows: for measurement areas exceeding 300 cm², alpha contamination shall not exceed 0.04 Bq/cm² and beta contamination shall not exceed 0.4 Bq/cm². 2.   Raw materials shall not contain explosive ordnance such as discarded bombs or artillery shells. 3.   Raw materials shall not include sealed containers, pressure vessels, or similar items. 4.   The mass percentage of hazardous waste in raw materials shall not exceed 0.01% of the total mass.
Shredded Recycled Iron and Steel Materials	Irregular fragmented or pelletized recycled steel feedstock produced from sorted, dismantled, and crushed materials including: automotive dismantling scrap, small or thin (<2.0mm) recycled materials, and industrial processing residues.		≤1.00%
Bundled Recycled Iron and Steel Materials	Dimensions: Length ≤1500mm, width ≤1000mm. Produced from automotive panels or other single-variety processing scraps/tailings, recycled rebar (threaded/wire rods), or crushed recycled steel feedstock through sorting and baling processes. Includes steel shavings and turnings generated during mechanical processing that undergo sorting, baling or bagging. The mass exceeding maximum dimensional specifications shall not exceed 5% of total mass.		≤0.80%
Recycled alloy steel feedstock	Dimensions: Length ≤1500mm, width ≤1000mm. Manufactured from: 1) Nickel-chromium or chromium series stainless steel scrap/processing remnants; 2) Decommissioned tool steel, die steel, bearing steel, gear steel, superalloys or silicon electrical steel components; 3) Processing by-products including alloy steel scraps, shavings and turnings - all processed through sorting, shearing, baling or bagging. The mass exceeding maximum dimensional specifications shall not exceed 5% of total mass.		≤0.80%
Recycled cast iron feedstock	Dimensions: Length ≤1500mm, width ≤600mm. Sourced from decommissioned cast iron products (minimum 2.0mm thickness) after service life expiration, or processing remnants/tailings from cast iron components, processed through sorting and shearing operations. The mass exceeding maximum dimensional specifications shall not exceed 5% of total mass.		≤0.80%

Note: Classification and specifications for recycled steel feedstock comply with China National Standard GB/T 39733.

 

 

I. Key Revisions

(I) Newly approved import category for recycled raw materials: Recycled black mass for lithium-ion batteries.

It is explicitly stated that recycled black mass materials for lithium-ion batteries meeting the annex requirements are not classified as solid waste and may be freely imported. These materials are categorized into two types: "Nickel- and/or cobalt-containing recycled black mass for lithium-ion batteries" and "Lithium iron phosphate (LFP)-containing recycled black mass for lithium-ion batteries."

(II) Revised categories and performance requirements for recycled steel raw materials.

1. The classification of recycled steel raw materials has been streamlined from seven categories (heavy-duty, medium-sized, small-scale, crushed, lump-type, alloy steel, and cast iron recycled steel raw materials) to five categories (ordinary recycled steel raw materials, crushed, lump-type, recycled alloy steel, and recycled cast iron raw materials). The former "heavy," "medium-sized," and "small" recycled steel raw materials are now consolidated under "ordinary recycled steel raw materials."

2. A new steel content requirement has been added to the performance indicators, specifying that all categories of recycled steel raw materials must contain no less than 92% steel by weight.

3. The inclusion requirements have been revised, transitioning from grade-specific inclusion criteria to uniform inclusion limits for each category.

(III) The commodity codes for recycled black mass raw materials and recycled steel raw materials used in lithium-ion batteries have been officially designated.

The HS code for recycled black mass raw material used in lithium-ion batteries is 3824999996.

The HS codes for recycled steel raw materials are 7204100010, 7204210010, 7204290010, 7204410010, and 7204490030.

(IV) Specify the performance requirements for recycled black mass raw materials and recycled steel raw materials used in lithium-ion batteries.

1. This revised announcement specifies the performance requirements for recycled steel raw materials and recycled black mass raw materials for lithium-ion batteries in the attached table, and clarifies that such materials meeting the requirements are not classified as solid waste and may be imported without restriction.

2. If customs suspects that imported recycled black mass raw materials for lithium-ion batteries or recycled steel raw materials may constitute solid waste, they may commission professional institutions to conduct attribute identification and manage them according to the identification results in accordance with the law.

(V) Specify the shipping, declaration requirements, and customs inspection methods for recycled black mass raw materials and recycled steel raw materials used in lithium-ion batteries.

1. Imported recycled black powder raw materials must not be mixed with other types of recycled raw materials and bulk packaging is prohibited. Different categories of recycled black powder materials shall be stored separately. During customs declaration, different types of recycled raw materials cannot be declared under the same customs declaration form. Imported recycled steel raw materials must not be mixed with other types of recycled raw materials. However, mixing is permitted when different categories of recycled steel materials have independent packaging, physical separation measures, or can be distinguished during unloading for classified discharge—provided they are stored separately. During customs declaration, different types of recycled raw materials cannot be declared under the same customs declaration form, though different categories of recycled steel materials may be declared together under a single form.

2. This announcement explicitly stipulates that the inspection of recycled black powder raw materials for lithium-ion batteries shall comply with Customs technical specifications to verify conformity with the requirements listed in the Appendix. For recycled steel raw materials, sensory inspection shall be primarily adopted. When conformity with the Appendix requirements cannot be determined through sensory inspection, testing shall be conducted according to Customs technical specifications, except for radioactive contamination inspections which must meet specialized Customs inspection requirements.

II. Frequently Asked Questions

Question 1: Must imported recycled black powder raw materials for lithium-ion batteries and recycled steel raw materials comply with national standards?

This announcement specifies the performance indicator requirements for recycled black powder raw materials and recycled steel raw materials for lithium-ion batteries in its Appendix. Imported recycled materials meeting these Appendix requirements are permissible for import. For indicators not included in the Appendix of national standards, buyers and sellers may negotiate terms during trade.

Question 2: Can independently packaged recycled black mass raw materials and recycled steel raw materials be imported in the same container and declared under a single customs declaration form?

No. Recycled black mass raw materials and recycled steel raw materials for lithium-ion batteries must not be mixed with other types of recycled raw materials. Different categories of recycled raw materials cannot be declared under the same customs declaration form.

Question 3: Under what circumstances would recycled black mass raw materials and recycled steel raw materials for lithium-ion batteries be subject to return shipment? What would be the consequences if the materials are identified as solid waste?

If customs authorities determine that imported recycled black mass raw materials or recycled steel raw materials for lithium-ion batteries fail to comply with regulatory requirements, the materials shall be returned. For materials suspected to be solid waste, customs may commission professional institutions for identification. Materials confirmed as solid waste shall be processed according to relevant laws and regulations. Therefore, enterprises must rigorously ensure quality and safety in imports by strengthening source control. Prior to shipment, they should require suppliers to verify that raw materials comply with regulatory requirements. This prevents scenarios where imported recycled materials fail to meet stipulated standards or are classified as solid waste, thereby avoiding unnecessary economic losses.

 

 

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 Disclaimer：The above content is translated from Chinese version of China Inspection and Quarantine Times. The China Inspection and Quarantine Times version shall prevail.