[SMM Analysis]Battery Recycling and Reuse – Vehicle Battery Swapping

Previously, six departments including the Ministry of Industry and Information Technology jointly issued the "Interim Measures for the Recycling and Comprehensive Utilization of Waste Power Batteries from New Energy Vehicles" (hereinafter referred to as the "Management Measures"), which will officially take effect on April 1, 2026. One of the most notable aspects of the new regulations is the clarification that the "vehicle-battery integrated retirement" requirement does not apply to battery-swapping car models. While this may appear as a technical exception, it actually highlights the unique value of the battery-swapping model in establishing a green, closed-loop system throughout the NEV life cycle.

One of the core provisions of the "Management Measures" is that NEVs must be retired with their power batteries intact. If the power battery is missing at the time of retirement, the vehicle will be considered incomplete, and the retirement process cannot be completed normally. The original intent of this provision is to prevent retired vehicle power batteries from entering gray markets, thereby strengthening the control over scarce metal resources and enhancing environmental protection.

For car models adopting the battery-swapping model, the policy provides special consideration. In battery-swapping models, the vehicle and the battery are inherently separate. Battery health management, and ultimately environmentally friendly recycling, are the responsibility of the enterprise. Users only need to use the vehicle normally without worrying about battery recycling. This "exception" is not a means to evade regulation but rather stems from the fact that the battery-swapping model inherently establishes a clearer and more easily regulated battery circulation path.

Enterprises must clarify the economic value of recycling and emphasize the final stage of the NEV value chain—recycling and utilization. This reveals an important trend: competition in the NEV sector has shifted from the first half focused on driving range and intelligence to the second half, which emphasizes refueling efficiency, life cycle costs, and environmental friendliness.