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On March 4, 2025, the Chinese Ministry of Ecology and Environment (MEE) opened a public consultation on the Announcement on the Import Control of Recycled Black Mass for Lithium-Ion Batteries and Recycled Iron-steel Materials (Draft). The comment period ended on March 20, 2025. This initiative aims to enhance resource recycling and optimize import control of recycled black mass used in lithium-ion batteries and recycled iron-steel materials.
Recycled black mass for lithium-ion batteries
Black mass refers to a black or gray-black powder obtained from end-of-life lithium-ion batteries, processed through procedures such as discharging, disassembly, pyrolysis, crushing, and separation, containing one or more valuable components such as lithium, nickel, and cobalt. In December 2024, China's State Administration for Market Regulation (SAMR) and Standardization Administration of China (SAC) issued GB/T 45203-2024 Recycled black mass for lithium ion battery to specify quality requirements for recycled black mass obtained from end-of-life lithium-ion batteries. This recommended national standard will take effect on July 1, 2025.
This time the Draft Announcement clarifies that recycled black masses for lithium-ion batteries that meet the specified criteria in the table below do not fall under the scope of solid wastes. They can be imported into China freely. The government encourages the import of recycled black mass as raw materials used in lithium-ion batteries.
If the proposal is adopted, HS codes will be assigned to ‘Recycled black mass for lithium-ion batteries containing nickel or (and) cobalt’ and ‘Recycled black mass for lithium-ion batteries containing lithium iron phosphate’.
Recycled iron-steel materials
In 2024, the SAMR and SAC released the national standard GB/T 39733-2024 Recycling iron-steel materials, which will take effect on June 1, 2025. This new standard supplements the types of recycled iron-steel materials and adds new indicators for the physical quantity of steel. While strictly distinguishing between recycled raw materials and solid wastes, it further expands the scope of high-quality recycled iron-steel materials. To align with GB/T 39733-2024, the Draft Announcement optimizes the import management of recycled iron-steel materials. Recycled iron-steel materials that meet the criteria specified in Annex 2 of the Draft Announcement can be imported freely.
Placement and customs declaration
Both recycled black masses and recycled iron-steel materials include different categories. Notably, according to the Draft Announcement, different categories should not be mixed. When declaring customs, different categories cannot be declared under the same customs declaration. Different categories must remain separate; however, they may be mixed if they have independent packaging, provided they are placed in a categorized manner.
