On April 28, 2026, China’s Ministry of Industry and Information Technology (MIIT) and four other central departments launched a nationwide special law enforcement campaign targeting illegal recycling and disposal of spent lithium-ion batteries. The action directly impacts the import compliance of regenerated selective catalytic reduction (SCR) catalysts used in marine exhaust aftertreatment systems—particularly those containing cobalt or nickel—due to tightened controls on traceability, export documentation, and customs classification of recycled metal feedstocks.

Event Overview

On April 28, 2026, MIIT, the Ministry of Ecology and Environment, the General Administration of Customs, the State Administration for Market Regulation, and the National Development and Reform Commission jointly initiated a special enforcement operation focused on the recycling and utilization of spent power batteries. Key enforcement targets include unauthorized dismantling, non-compliant export practices, and absence of full-lifecycle material traceability records for regenerated metals.

Industries Affected

Direct Trading Enterprises: Exporters and international traders supplying regenerated cobalt/nickel-based SCR catalysts—or precursor materials—to EU, Korean, and other regulated markets face heightened pre-shipment verification requirements. Non-possession of the official Customs Commodity Code for Regenerated Metal Raw Materials and auditable traceability documentation may trigger customs delays, rejections, or post-import environmental compliance audits in destination countries.

Raw Material Procurement Enterprises: Companies sourcing regenerated cobalt, nickel, or mixed oxide powders from Chinese recyclers must now validate upstream compliance—not only with China’s new enforcement criteria but also with downstream regulatory expectations (e.g., EU Battery Regulation Annex VII due diligence). Absence of verifiable chain-of-custody records increases procurement risk and may invalidate supplier declarations under corporate ESG reporting frameworks.

Processing and Manufacturing Enterprises: Catalyst formulators and system integrators relying on imported regenerated metal feedstocks face extended lead times and supply uncertainty. Process validation—including chemical composition consistency and impurity profile repeatability—may require requalification if raw material provenance shifts abruptly due to supplier non-compliance or operational suspension.

Supply Chain Service Providers: Third-party logistics firms, customs brokers, and certification bodies supporting cross-border catalyst trade must update documentation protocols and internal audit checklists. Services such as origin verification, material passport validation, and customs code alignment are now mission-critical—not optional—for client retention and regulatory defensibility.

Key Points for Enterprises and Practitioners to Monitor and Address

Verify Customs Code Alignment Immediately

Confirm whether your Chinese suppliers hold and correctly apply the official Customs Commodity Code for Regenerated Metal Raw Materials. Misclassification—even if historically accepted—now carries enforcement consequences under the joint directive.

Implement Full-Lifecycle Traceability Documentation

Require suppliers to provide digitally accessible, tamper-evident traceability records covering battery origin, dismantling batch, metallurgical process route, and final material assay reports. Paper-based or fragmented logs no longer satisfy enforcement-grade verification standards.

Assess Dual-Regime Compliance Exposure

Evaluate exposure across both Chinese outbound controls (e.g., export licensing, environmental permits) and importing-country obligations (e.g., EU CBAM-aligned due diligence, Korea’s Green New Deal import conditions). Discrepancies between regimes may expose gaps in current compliance architecture.

Editorial Perspective / Industry Observation

This enforcement is not merely a recycling-sector initiative—it signals a structural shift toward embedding circularity requirements into high-value industrial inputs. Observably, the focus on cobalt/nickel-based SCR catalysts reflects growing recognition that battery recycling infrastructure is now a strategic node for emissions-critical marine technologies. Analysis shows the move strengthens China’s leverage in global clean shipping supply chains—not by restricting trade, but by raising the bar for data integrity and material accountability. From an industry perspective, this is better understood as a calibration of enforcement rigor than a policy reversal: traceability was already mandated under the 2023 Regulations on Management of Spent Power Battery Recycling, but enforcement capacity and inter-departmental coordination have now matured.

Conclusion

The April 28 action underscores that environmental compliance in advanced marine emission control is increasingly inseparable from upstream material governance. For global stakeholders, this reinforces the need to treat supply chain transparency—not just product performance—as a core technical specification. A rational interpretation is that regulatory convergence around battery-derived critical metals will accelerate, making proactive traceability integration less a competitive differentiator and more a baseline operational requirement.

Source Attribution

Official announcement issued jointly by MIIT, MEE, GACC, SAMR, and NDRC on April 28, 2026; supplementary guidance referenced from the Administrative Measures for the Traceability System of Spent Power Batteries (2023 Revision) and the Customs Tariff Classification Rules for Regenerated Metal Raw Materials (GACC Notice No. 17/2025). Ongoing updates to provincial-level implementation guidelines and customs clearance templates remain under observation.