China Suspends Lithium Battery and Material Export Controls for One Year [SMM Analysis]

On October 30, according to information from the Ministry of Commerce, China will suspend for one year the export control measures on lithium batteries and related materials announced on October 9, within the framework of the consensus reached during the China-U.S. Kuala Lumpur economic and trade consultations. Further refinement of supporting plans will be studied based on subsequent developments. Industry insiders indicated that the suspension involves high-performance lithium-ion batteries, battery manufacturing equipment, and key raw materials (such as artificial graphite, cathode and anode materials, etc.) that were previously proposed to be included in export licensing management. In the short term, this will help alleviate market concerns over uncertainties in export approvals and stabilize supply-demand expectations across the upstream and downstream sectors. Analysis suggests that the policy adjustment signals a phased easing in China-U.S. economic and trade relations, which is conducive to the execution of export orders and the restoration of international cooperation in the lithium battery industry chain. However, the market still needs to pay attention to the policy direction and detailed rule changes after the one-year suspension period expires.

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

In accordance with 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 non-proliferation obligations, approved by the State Council, it is decided to implement export controls on the following items:

I. Items Related to Lithium Batteries

(1) 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).

(2) 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.

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

II. Items Related to Cathode Materials(I) 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 (refer to tariff code: 28429040).

(II) 3C901.a.2. Precursor-related items for ternary cathode materials:

a. Nickel-cobalt-manganese hydroxide (refer to tariff code: 28539030);

b. Nickel-cobalt-aluminum hydroxide (refer to tariff code: 28539050).

(III) 3C901.a.3. Lithium-rich manganese-based cathode material.

(IV) 3B901.b. Equipment used for manufacturing rechargeable lithium-ion battery cathode materials:

1. Roller hearth kiln;

2. High-speed mixer;

3. Sand mill;

4. Air jet mill.

III. Graphite Anode Material-Related Items

(I) 3C901.b.1. Artificial graphite anode material.

(II) 3C902.b.2. Anode material composed of a mixture of artificial graphite and natural graphite.

(III) 3B901.c.1. Granulation process equipment used 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.

(IV) 3B901.c.2. Graphitisation equipment used for producing graphite anode materials:

a. Box furnace;

b. Acheson furnace;

c. Internal series furnace;

d. Continuous graphitisation furnace.

(V) 3B901.c.3. Coating modification equipment used 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.

(VI) 3E901.b. Processes and technologies used for producing graphite anode materials:

1. Granulation process;

2. Continuous graphitisation technology;

3. Liquid-phase coating technology.

Operators exporting the above-mentioned items shall apply to the competent department of commerce under the State Council for a license 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 and enhance the identification of export items. If the items fall under controlled items, they must indicate "dual-use items" in the remarks column of the customs declaration form and specify the export control codes for dual-use items. If the items are not controlled items but their parameters, indicators, or performance are close to those of controlled items, they must indicate "not controlled items" in the remarks column and provide specific parameters and indicators. If customs authorities have doubts about the completeness, accuracy, or authenticity of the above-declared information, they will raise inquiries in accordance with the law, and during the inquiry period, the export goods will not be released.

This announcement shall take effect from November 8, 2025. The "Export Control List of Dual-Use Items of the People's Republic of China" will be updated simultaneously.