New Regulations on Import of Lithium-ion Battery Recycled Black Powder and Recycled Steel Raw Materials: Key Points for International Shippers
—— A Focus on Importing Recycled Materials into China
Introduction
As a leading international freight forwarder based in Shenzhen, China, we are writing to inform our global clients, especially overseas buyers sourcing from China, about crucial regulatory updates that will impact the logistics of certain recyclable commodities. Effective August 1, 2025, a joint announcement by six Chinese ministries (including the Ministry of Ecology and Environment and the General Administration of Customs) introduces new rules for the import of Lithium-ion Battery Recycled Black Powder and Recycled Steel Raw Materials. Understanding these changes is vital for ensuring smooth customs clearance and avoiding shipment delays or rejections.
1. What's New? Key Regulatory Changes
A. A New Commodity is Now Freely Importable: Lithium-ion Battery Recycled Black Powder
A significant development is the official recognition of Lithium-ion Battery Recycled Black Powder as a non-solid-waste renewable raw material, allowing its free import into China. This material is categorized into two types:
- Type 1: Containing Nickel and/or Cobalt Elements
- Type 2: Containing Lithium Iron Phosphate (LFP)
Critical for Shippers: To qualify for free import (non-solid-waste status), the black powder must strictly meet the technical specifications outlined in the regulation's annex. Key indicators include minimum percentages of valuable metals (e.g., Ni+Co ≥25.00% for Type 1; Fe ≥18.00%, Li ≥2.00% for Type 2), maximum limits for impurities (e.g., Zinc ≤0.10%), and physical properties (e.g., particle size). Materials failing these standards may be classified as solid waste, leading to mandatory re-export (return) and potential penalties.
B. Revised Classification and Standards for Recycled Steel Raw Materials
The classification for recycled steel has been streamlined from seven to five categories:
- Ordinary Recycled Steel Raw Materials
- Shredded Recycled Steel Raw Materials
- Bundled Recycled Steel Raw Materials
- Recycled Alloy Steel Raw Materials
- Recycled Cast Iron Raw Materials
A new universal requirement mandates that the steel content for all categories must be no less than 92.0%. Contaminant limits are now standardized per category rather than by sub-grade.
2. Logistics & Customs Declaration: What You Must Know
A. Harmonized System (HS) Codes
| Commodity | HS Code(s) |
|---|---|
| Lithium-ion Battery Recycled Black Powder | 3824 99 9996 |
| Recycled Steel Raw Materials | 7204 10 0010, 7204 21 0010, 7204 29 0010, 7204 41 0010, 7204 49 0030 |
B. Stowage and Packaging Rules
Strict segregation rules apply during transport:
- Recycled Black Powder: Bulk shipment is PROHIBITED. It must not be mixed with any other type of recycled raw material in the same container. Different categories of black powder (Ni/Co vs. LFP) must also be stored separately.
- Recycled Steel: It must not be mixed with other kinds of recycled raw materials (e.g., black powder). However, different categories of recycled steel (e.g., Shredded and Bundled) may be co-loaded in one container ONLY IF they are in independent packaging, physically separated, or can be distinguished and discharged separately. Proper separation must be verifiable.
C. Customs Inspection Procedures
Black Powder: Will be inspected according to Customs industry technical specifications to verify compliance with the annex.
Recycled Steel: Customs will first apply a visual (sensory) inspection. If compliance cannot be determined visually, technical specification-based inspection will be conducted. All shipments are subject to radiation level checks.
D. Declaration (Critical)
A single customs declaration form must not declare different kinds of recycled raw materials. For example, you cannot declare Recycled Black Powder and Recycled Steel on the same form.
A single declaration form may declare different categories of Recycled Steel Raw Materials (as they are the same "kind").
3. Risk Mitigation & Proactive Advice for International Buyers
To prevent costly delays, re-export orders, or legal issues, we strongly advise our clients to:
- Conduct Pre-Shipment Quality Assurance: Work closely with your Chinese suppliers to ensure the raw materials strictly comply with the new technical specifications (composition, contaminants, etc.) before shipment. Request certified laboratory analysis reports if necessary.
- Verify Supplier Documentation: Ensure the supplier provides accurate descriptions, HS codes, and all necessary documentation aligned with the new rules.
- Plan Packaging and Stowage Carefully: Adhere to the strict no-mixing rules. For black powder, ensure proper packaging (no bulk) and segregation. For mixed steel categories, implement clear physical separation within the container.
- Engage Experienced Forwarders: Partner with a freight forwarder (like us) with expertise in handling regulated commodities and complex customs clearance procedures in China. We can guide you on documentation, stowage plans, and declaration specifics.
Conclusion
These new regulations standardize the import process for key recycled materials, supporting a circular economy. While they introduce stricter compliance requirements, understanding and adhering to the rules on product specs, HS codes, segregation, and declaration is the key to seamless logistics. As your logistics partner, we are here to navigate these changes with you. Please contact our hazardous materials/recyclables logistics team for specific consultations related to your shipments.
Disclaimer: This article is for informational purposes based on the official announcement. Regulations are subject to change. Always consult with official sources or professional advisors for critical decisions.