Public Notice from the Ministry of Ecology and Environment of China Regarding the Import of Recycled Materials for Lithium-Ion Batteries

On February 28, 2025, the Ministry of Ecology and Environment of China published the “Public Notice on the Standardization of Import Management for Recycled Black Mass Materials and Recycled Steel Materials for Lithium-Ion Batteries (Draft for Comments).” This notice aims to regulate the import management of recycled black mass materials and recycled steel materials for lithium-ion batteries. The comment period for this draft is open until March 20, 2025. The main contents of the draft are as follows:

Recycled Black Mass Materials

According to Table 1 of the draft, the following two types of materials are classified as recycled black mass materials:

• Materials containing nickel or cobalt, or both.
• Materials containing lithium iron phosphate.

Table 1 also specifies the content rates of each substance.

Recycled Steel Materials

According to Table 2 of the draft, the following seven types of materials are classified as recycled steel materials:

• Heavy recycled steel materials: Waste steel with a thickness of 6.0 mm or more or a diameter of 10 mm or more.
• Medium recycled steel materials: Waste steel with a thickness of 4.0 mm or more or a diameter of 8 mm or more.
• Small recycled steel materials: Waste steel with a thickness of 2.0 mm or more.
• Shredded recycled steel materials: Waste steel from automobile dismantling materials with a thickness of less than 2.0 mm.
• Chunky recycled steel materials: Waste steel such as automotive steel plates.
• Recycled alloy steel materials: Waste alloy materials containing nickel, cobalt, etc.
• Recycled cast iron materials: Waste cast iron with a thickness of 2.0 mm or more.

Table 2 specifies the steel content rate to be 92.0% or more and also regulates the impurity content rate.

Import Management Requirements

• Recycled black mass materials that meet the requirements of Table 1 are not classified as solid waste and can be freely imported. Mixing different types of recycled black mass materials listed in Table 1 is not permitted.
• Recycled steel materials that meet the requirements of Table 2 are also not classified as solid waste and can be freely imported. Mixing different types of recycled steel materials listed in Table 2 is not permitted.
• The inspection of recycled materials will be conducted based on customs technical standards. Recycled black mass materials and recycled steel materials for lithium-ion batteries imported into China must meet the requirements of this public notice.

The original text of the above public notice (in Simplified Chinese) can be viewed at the following website:
https://www.mee.gov.cn/xxgk2018/xxgk/xxgk06/202503/t20250304_1103276.html