[SMM Analysis] China Implements Export Controls on Lithium Batteries and Key Materials, Covering High-End Batteries and Artificial Graphite Anodes

On October 9, 2025, the Ministry of Commerce and the General Administration of Customs jointly issued Announcement No. 58 of 2025, deciding to implement export controls on items related to lithium batteries, cathode materials, and graphite anode materials. The measure will take effect on November 8, 2025, aiming to safeguard national security and interests and fulfill international obligations such as non-proliferation.

According to the announcement, the controlled items include high-end lithium-ion batteries with a gravimetric energy density greater than or equal to 300 Wh/kg, key battery production equipment, various cathode materials and their precursors, as well as artificial graphite anode materials and related production equipment and technology.

This is the latest development in a series of control measures by China in the field of key mineral resources, following similar controls previously implemented on battery cathode material preparation technology and rare earth items.

Original announcement:

Ministry of Commerce, General Administration of Customs Announcement No. 58 of 2025 on the Decision to Implement Export Controls on Items Related to Lithium Batteries and Artificial Graphite Anode Materials

Pursuant to the provisions of the Export Control Law of the People's Republic of China, the Foreign Trade Law of the People's Republic of China, the Customs Law of the People's Republic of China, and the Regulations of the People's Republic of China on the Export Control of Dual-Use Items, and in order to safeguard national security and interests and fulfill international obligations such as non-proliferation, approved by the State Council, it is decided to implement export controls on the following items:

I. Items related to lithium batteries

(a) 3A001 Rechargeable lithium-ion batteries (including battery cells and battery packs) with a gravimetric energy density greater than or equal to 300 Wh/kg (Reference tariff line: 85076000).

(b) 3B901.a. Equipment used for manufacturing rechargeable lithium-ion batteries:

1. Winding machines (Reference tariff line: 84798999);

2. Stacking machines (Reference tariff line: 84798999);

3. Electrolyte filling machines (Reference tariff line: 84798999);

4. Hot pressing machines;

5. Formation and capacity grading systems;

6. Capacity grading cabinets.

(c) 3E901.a. Technology used for producing the items controlled under item 3A001.

II. Items related to cathode materials

(a) 3C901.a.1. LFP cathode material with a compaction density greater than or equal to 2.5 g/cm³ and a capacity per gram greater than or equal to 156 mAh/g (Reference tariff line: 28429040).

(b) 3C901.a.2. Items related to precursors for ternary cathode materials:

a. Nickel-cobalt-manganese hydroxide (Reference tariff line: 28539030);

b. Nickel Cobalt Aluminum Hydroxide (Refer to Tariff Heading: 28539050).

(c) 3C901.a.3. Lithium-rich Manganese-based Cathode Material.

(d) 3B901.b. Equipment for Manufacturing Rechargeable Lithium-ion Battery Cathode Materials:

1. Roller Hearth Kiln;

2. High-speed Mixer;

3. Sand Mill;

4. Airflow Crusher.

III. Graphite Anode Material Related Items

(a) 3C901.b.1. Artificial Graphite Anode Material.

(b) 3C902.b.2. Anode Material Composed of a Mixture of Artificial Graphite and Natural Graphite.

(c) 3B901.c.1. Granulation Process Equipment for Producing Graphite Anode Materials:

a. Vertical Granulation Reactor with a Granulation Volume Greater Than or Equal to 5 m³;

b. Continuous Granulation Reactor with a Granulation Volume Greater Than or Equal to 5 m³.

(d) 3B901.c.2. Graphitisation Equipment for Producing Graphite Anode Materials:

a. Box Furnace;

b. Acheson Furnace;

c. Internal Series Furnace;

d. Continuous Graphitisation Furnace.

(e) 3B901.c.3. Coating Modification Equipment for Producing Graphite Anode Materials:

a. Fusion Coating Equipment with a Volume Greater Than 300 L;

b. Spray Drying Equipment with a Volume Greater Than 60 m³;

c. Chemical Vapor Deposition (CVD) Rotary Kiln with a Barrel Diameter Greater Than 0.5 m.

(f) 3E901.b. Processes and Technologies for Producing Graphite Anode Materials:

1. Granulation Process;

2. Continuous Graphitisation Technology;

3. Liquid Phase Coating Technology.

Export operators exporting the aforementioned items shall apply for a license from the competent department of commerce under the State Council in accordance with the relevant provisions of the Export Control Law of the People's Republic of China and the Regulations of the People's Republic of China on the Export Control of Dual-Use Items.

Export operators shall be responsible for the authenticity of declared goods, strengthen the identification of export items. For items subject to control, they must indicate "Subject to Dual-Use Items" in the remarks column of the customs declaration form and list the export control code for dual-use items; for items not subject to control but with parameters, indicators, or performance close to controlled items, they must indicate "Not Subject to Controlled Items" in the remarks column and provide specific parameters and indicators. If the completeness, accuracy, or authenticity of the above declaration information is in doubt, customs will question it according to law, and during the questioning period, the export goods will not be released.

This announcement shall take effect from November 8, 2025.《The Catalogue of Controlled Exports of Dual-Use Items of the People's Republic of China was updated simultaneously.

Ministry of Commerce, General Administration of Customs

Oct 9, 2025

SMM Analysis

I. Comprehensive Coverage of Control Scope: From Battery Products to Manufacturing Technology

According to Announcement No. 58 of 2025 issued by the Ministry of Commerce and the General Administration of Customs, the export control measures cover multiple key segments of the lithium-ion battery industry chain.

For high-end lithium-ion batteries, the controls target rechargeable lithium-ion batteries with a gravimetric energy density greater than or equal to 300 Wh/kg, including battery cells and battery packs.

This technical specification far exceeds the level of ordinary power batteries and covers the most advanced battery products currently available.

Battery manufacturing equipment has also been included in the control scope, including core equipment such as winding machines, stacking machines, electrolyte filling machines, hot presses, formation and capacity grading systems, and capacity grading cabinets.

These equipment are crucial for building battery production lines and directly affect the performance and quality of battery products.

In the field of cathode materials, the controls involve high-compaction density LFP materials (compaction density ≥2.5 g/cm³ and capacity per gram ≥156 mAh/g), precursors for ternary cathode materials (nickel-cobalt-manganese hydroxide, nickel-cobalt-aluminum hydroxide), and lithium-rich manganese-based cathode materials.

For graphite anode materials, artificial graphite anode materials and their mixtures with natural graphite are included in the controls.

Simultaneously, pelletizing process equipment, graphitisation equipment, and coating modification equipment used for producing graphite anode materials, as well as related process technologies, are also restricted.

II. Precise Policy Layout: Balancing Security Maintenance and Industry Support

The introduction of this policy follows China's consistent approach of precise control in key strategic resource areas.

From a legal basis perspective, this measure is implemented with the approval of the State Council, based on relevant provisions of the Export Control Law of the People's Republic of China, the Foreign Trade Law of the People's Republic of China, the Customs Law of the People's Republic of China, and the Regulations on the Export Control of Dual-Use Items.

When explaining similar measures, a spokesperson for the Ministry of Commerce stated that this is a "specific measure to adapt to changes in China's technological development landscape and improve the management of technology trade," aiming to "safeguard national economic security and development interests, and promote international economic and technological cooperation."

From a technical dimension analysis, this control focuses on high-end lithium batteries and materials, and does not involve the entire industry chain.

For example, only high-end batteries with an energy density ≥300 Wh/kg are restricted, a standard that is higher than the level of most current power batteries.

Similarly, for graphite materials, only high-end products meeting specific technical indicators are subject to controls, while ordinary graphite materials remain unaffected.

III. Far-Reaching Industrial Impact: Reshaping the Global Battery Supply Chain Landscape

China dominates the global lithium battery industry chain, and these export restrictions will significantly impact the localization of overseas lithium battery manufacturing.

According to industry data, China holds over 70% of the global market share in both cathode and anode materials for lithium batteries, and its capacity accounts for more than 80% of the battery manufacturing segment.

The introduction of these control measures will directly affect the global supply landscape for high-end battery products.

International battery producers may face supply deficits of high-end lithium-ion batteries or need to accelerate their own R&D and capacity building.

Overseas NEV automakers relying on high-end battery products may face supply chain adjustment pressures and need to reassess battery technology routes and supplier choices.

For the domestic industry chain, short-term market adjustment pressures are possible, but in the long term, it will help maintain China's leading advantage in the high-end battery sector.

Meanwhile, the policy will prompt Chinese battery enterprises to focus more on the domestic market and accelerate the application and promotion of domestic high-end battery technology.

IV. Corporate Compliance Guidance: Clarifying Declaration Requirements and Legal Responsibilities

According to the announcement, operators exporting the aforementioned items must apply for a license from the competent commerce department of the State Council in accordance with relevant regulations.

Enterprises are responsible for the authenticity of declared goods and must strengthen the identification of export items.

For items subject to control, the remark column of the customs declaration form must indicate "Subject to dual-use items" and list the dual-use item export control code; for items not subject to control but with parameters, indicators, or performance close to controlled items, the remark column must state "Not subject to control items" and provide specific parameters and indicators.

If the completeness, accuracy, or authenticity of the declared information is in doubt, customs will question it according to law, and export goods will not be released during the questioning period.

Enterprises need to establish comprehensive internal compliance mechanisms to conduct strict reviews of intended export items, ensuring they meet regulatory requirements.

If it is uncertain whether an item is subject to control, official channels should be consulted to avoid legal liability due to non-compliant exports.

V. Conclusion

With the introduction of China's export control measures, battery enterprises in Japan and South Korea, Europe, and the United States will face dual challenges in sourcing high-end materials and accessing technology. In the short term, global high-end EVs and high-energy-density energy storage system projects may face supply chain pressures. Meanwhile, China's power battery industry, driven by the dual objectives of national security and industrial competitive advantage, has entered a new phase of development.