New Regulations for Regenerated Black Powder (Lithium Battery) and Steel Scrap Imports: Key Points for International Buyers Shipping to/from China
Introduction
Effective August 1, 2025, a new joint regulation (Announcement No. 14 of 2025) issued by six Chinese ministries, including the Ministry of Ecology and Environment and the General Administration of Customs, significantly updates the import management framework for two critical categories of recycled raw materials: Lithium-ion Battery Regenerated Black Powder and Regenerated Steel Raw Material. This is crucial for all international buyers, procurement managers, and logistics partners involved in sourcing these materials from or through China. The announcement clarifies that materials meeting specified standards are not classified as solid waste, thereby liberalizing their import. This document provides a key summary from an international logistics and transportation perspective.
1. Key Changes and What They Mean for Your Shipment
1.1. A New Importable Commodity: Lithium-ion Battery Regenerated Black Powder
What it is: "Black Powder" is a recycled material derived from processed lithium-ion battery waste, now approved for import. It is categorized into two types:
- Nickel/Cobalt-containing Regenerated Black Powder.
- LFP (Lithium Iron Phosphate)-containing Regenerated Black Powder.
Logistics & Customs Impact:
- HS Code: A dedicated HS code has been assigned: 3824 99 9996. Accurate declaration under this code is mandatory.
- Not Solid Waste: Meeting the technical specs (see below) is critical for smooth customs clearance, as it exempts the shipment from stringent solid waste controls.
1.2. Revised Classification and Standards for Regenerated Steel
Simplified Categories: The previous seven categories are consolidated into five, streamlining classification:
- Ordinary Regenerated Steel Material
- Shredded Regenerated Steel Material
- Bundled Regenerated Steel Material
- Regenerated Alloy Steel Material
- Regenerated Cast Iron Material
Unified Quality Thresholds:
- Steel Content: A new, universal minimum of ≥92% steel content is required for all categories.
- Impurity Limits: Impurity limits are now standardized per category, simplifying compliance checks.
Logistics & Customs Impact:
- HS Codes: Designated codes are 7204 10 0010, 7204 21 0010, 7204 29 0010, 7204 41 0010, 7204 49 0030. Correct classification is essential.
2. Critical Logistics, Packing, and Customs Declaration Requirements
Non-compliance with these operational rules can lead to inspections, delays, or rejection at the port.
2.1. Packing and Stowage (Especially for Container Shipments)
| Material | Rules for Mixing/Stowage |
|---|---|
| Regenerated Black Powder |
|
| Regenerated Steel Material |
|
2.2. Customs Declaration (A Must-Read for Forwarders & Declarants)
- One Commodity Type Per Declaration: A single customs declaration form cannot declare different kinds of regenerated raw materials. For example, Black Powder (3824...) and Steel Scrap (7204...) must be declared on separate forms.
- Multiple Steel Categories on One Form Allowed: Different categories of Regenerated Steel Material (all under 7204 codes) can be declared on the same form, provided the packing/stowage rules above are followed.
3. Compliance, Inspection, and Risk of Rejection
The Golden Rule: Imported materials must conform to the technical specifications detailed in the regulation's annex. This is the buyer's and shipper's responsibility.
Customs Inspection Process:
- Black Powder: Subject to inspection per Customs technical standards to verify compliance with the annex specifications.
- Steel Scrap: Primarily inspected via visual/sensory check. If compliance is uncertain, technical inspection follows. All shipments undergo mandatory radiation checks.
Consequences of Non-Compliance:
- Rejection/Return: Materials failing to meet the regulatory specifications will be denied entry and require re-shipment at the consignee's expense.
- Solid Waste Designation: If Customs suspects the cargo to be solid waste, they will appoint a professional agency for identification. If confirmed as solid waste, the shipment will be handled under China's strict solid waste management laws, potentially leading to severe penalties, forced return, or destruction.
4. Actionable Advice for International Buyers and Shippers
- Conduct Pre-Shipment Due Diligence: The most critical step. Buyers must ensure their Chinese suppliers provide a Certificate of Analysis (CoA) or equivalent proof that the material batch complies with all technical indicators (e.g., elemental content, impurity levels, size specs) before shipment. Do not rely on assurances alone; demand data.
- Engage Knowledgeable Logistics Partners: Work with a freight forwarder and customs broker in China who has specific expertise in handling regulated recycled materials and is fully aware of this new announcement. They can guide you on proper packing, documentation, and HS code application.
- Ensure Precise Documentation: Commercial invoices and packing lists must accurately describe the goods, specifying the exact category (e.g., "Shredded Regenerated Steel Material, HS 7204 41 0010") and reference the relevant standard. Consistency across all documents is key.
- Plan for Segregated Shipments: For Black Powder, plan and book dedicated container space. For mixed steel categories, ensure physical separation is planned and documented in the stowage plan.
Conclusion
These new regulations standardize and facilitate the legal import of valuable recycled battery and steel materials into China. The path to smooth logistics hinges on strict technical compliance, meticulous packing/declaration, and proactive verification. Failure to adhere to these rules will result in significant logistical disruptions, financial losses, and regulatory exposure. Prioritizing compliance from the sourcing stage is not just recommended—it is essential for a successful and efficient supply chain.
Quick Reference Summary
| Commodity | HS Codes | Key Restrictions |
|---|---|---|
| Lithium-ion Battery Regenerated Black Powder | 3824 99 9996 | No mixing with other materials; No bulk shipment; Separate categories |
| Regenerated Steel Raw Materials | 7204 10 0010, 7204 21 0010, 7204 29 0010, 7204 41 0010, 7204 49 0030 | ≥92% steel content; Cannot mix with non-steel materials; Steel categories may co-load with physical separation |
Disclaimer: This guide is for informational purposes based on official Announcement No. 14 of 2025. Regulations are subject to change. Always consult official sources or professional customs brokers for specific shipments.