China battery and graphite exports: separate suspended controls, active licences and dangerous-goods rules
Bottom line: As of 2026-08-23, the lithium-ion batteries at ≥300 Wh/kg, battery-manufacturing equipment, cathode materials, artificial-graphite anode materials and related technologies listed in MOFCOM/GACC Notice No. 58 of 2025 are suspended through 2026-11-10 under Notice No. 70. They must not currently be labelled as automatically requiring a dual-use export licence under Notice No. 58. However, graphite covered by 1C108.a/b/c, certain lithium-thionyl-chloride batteries under 1C450.c.14, and transactions involving sensitive end uses or end users remain controlled. Even when an ordinary lithium battery does not require a dual-use licence, customs dangerous-goods packaging appraisal and carrier requirements such as UN38.3 may still apply.
Latest valid status: No.58 The suspension of the number does not mean that all lithium batteries and graphite can be exported freely.
It should be judged layer by layer based on the announcement release time and whether it is suspended; it cannot be read-only.2025 year 58 The original text of the No. 1 omitted the No. 1 document issued before it took effect the next day.70 No. suspension decision.
| regulations | As of 2026-08-23 Status | practical impact |
|---|---|---|
| 2025 year 58 No. | Pause to 2026-11-10 | Original lithium-ion batteries, manufacturing equipment, cathode/anode materials and technologies are currently not required to be licensed under this announcement. |
| 2025 year 70 No. | Currently valid | since 2025-11-07 Starting and pausing 55,56,57,58,61,62 No. arrived 2026-11-10. |
| 2023 year 39 No./1C108 | Currently valid | Specific artificial graphite, natural flake graphite and their products still require a dual-use item export license. |
| 1C450.c.14 | Currently valid | Thionyl chloride and related batteries that exceed the explicit exclusion conditions must still be checked. |
| Dangerous goods packaging and transportation | Effective separately | Whether hazardous package performance/use identification and shipping documents are required are two separate systems from dual-use item licensing. |
Date to be reviewed:No.70 The number is only written to 2026-11-10. The website and trading rules should be re-checked for the official announcement before and after that date, and it cannot be assumed that the 58 The account is permanently invalid and cannot be automatically restored in advance.
Let’s first distinguish between the three systems
| system | Answered questions | Common files | cannot be confused with |
|---|---|---|---|
| Export controls on dual-use items | Whether specific goods, equipment, software or technology can be transferred from China to overseas. | Department of Commerce Export License for Dual-Use Items, End-User and End-Use Certification. | UN38.3 Or dangerous package certificate. |
| Restriction on export of technology | Can the process, formula, parameters, drawings, and technical services be provided overseas? | "Application Form for China's Restricted Export of Technology", technology export license and contract registration. | Dual-use item permission for the goods themselves. |
| Customs and dangerous goods transportation | Whether the battery can be safely packaged, declared and transported according to the selected sea, air and express delivery methods. | Dangerous package performance/use identification, hazardous characteristics classification information, carrier requirements UN38.3 Wait. | China Export Control License. |
Eight-step check for buyers and exporters
1Confirm actual items
Obtain the complete model, chemical system, cell/battery pack, rated energy, weight, gravimetric energy density, electrolyte or thionyl chloride filling volume; for graphite, obtain the source, form, purity, flexural strength, density and whether it contains natural flake graphite.
2Don't use it first HS Code draw conclusions
HS Can only assist with screening.85076000It does not mean that the entire tax code is currently subject to the 58 No. control; the same tax number for graphite may also have only part of the technical description hit.
3First remove the currently suspended 58 No.
If the only reason to hit is3A001,3B901,3C901,3C902 or 3E901, should currently be marked with "Suspension Measures/2026-11-10 Check again before and after" and cannot directly request permission for the announcement.
4Compare the current word-for-word 1C108 with 1C450
Graphite needs to be checked1C108.a/b/c;Thionite chloride batteries need to be inspected1C450.c.14substances and explicit exclusion conditions.
5Check technology export
If the transaction includes recipes, process packages, drawings, equipment calibration, remote technical services or overseas line construction, check separately.252604Xwith083201X, don’t just judge the physical goods.
6Screen end users, uses and destinations
Even if it is not included in the list, if you know or should know that it may be used for weapons of mass destruction, their delivery vehicles, terrorism or other purposes that endanger national security interests, you may still trigger a blanket license.
7Decide on application, consultation or general export
If it is clear that there is a hit, obtain permission first; if the parameters are incomplete or close to the threshold, the Chinese exporter should submit an item identification consultation to the Ministry of Commerce; if it is clear that there is no hit, the determination data will be saved.
8Final processing of dangerous packages and conditions of carriage
Confirm the performance/usage appraisal of the dangerous package with the customs where the production enterprise is located, and confirm the battery status, charge level, packaging, marking, etc. with the actual carrier.UN38.3 and route restrictions.
Lithium battery/graphite related dual-use items that are still valid
| control code | Current technology description | 2026 Reference customs commodity number | result |
|---|---|---|---|
1C108.a | Also consistent with: Density>1.72 g/cm ³. Tensile breaking strain ≥0.7%, thermal expansion coefficient ≤2.75×10⁻⁶/℃ artificial fine grained monolithic graphite. | 3801100040 | Apply for a dual-use permit first |
1C108.b | Artificial graphite materials and their products also comply with: Purity>99.9%, flexural strength>30 MPa, density>1.73 g/cm ³. | 380110004038019090106815190020 | Apply for a dual-use permit first |
1C108.c | Natural flake graphite and its products, including spheroidized graphite, expanded graphite, etc. | 250410100025041091003801901000380190901038249999216815190020 | Apply for a dual-use permit first |
1C450.c.14 | Thionyl chloride/sulfurous chloride/sulfur oxychloride; expressly excluded "The filling amount of thionyl chloride in a single lithium thionyl chloride battery or battery pack is ≤1 kg”. | 28121700008506500019 | Judgment based on filling volume and items |
2026 Customs item numbers in the catalog reflect tariff adjustments, and 2023 year 39 The original numbers listed in the announcement may be different. The technical description still takes precedence in the judgment, and the same HS All goods are subject to regulation.
Preliminary determination of common lithium battery products
| Product/Conditions | Preliminary judgment on dual-use items | what still to do |
|---|---|---|
| Lithium-ion batteries for ordinary mobile phones, laptops, cameras, tools or batteries installed with the equipment | Usually not due to 58 Apply for permission | Confirm there are no other controlled functions or sensitive uses; confirm with the carrier the packaging rules for batteries and equipment. |
| General power bank, electric bicycle/scooter battery pack | No.58 The number is currently suspended | May still be dangerous goods; confirmed Wh, battery status,UN38.3, packaging and shipping. |
| Weight energy density ≥300 Wh/kg of rechargeable lithium-ion cells or battery packs | 3A001 Pause to 2026-11-10 | Test data is saved and reviewed upon expiration; highly sensitive applications are still subject to full review. |
| Lithium thionite chloride battery, single cell/battery group thionite chloride filling amount ≤1 kg | excluded from 1C450.c.14 | The exclusion only applies to this control code; the transportation of dangerous goods and other applicable regulations are still dealt with. |
| Lithium thionite chloride battery, filling quantity unknown or exceeding 1 kg | Requires item identification/possible clearance | Obtain the manufacturer's certificate of ingredients and filling quantity, and consult or apply for it from the Chinese exporter. |
| Any battery used in military, missile, nuclear, biological or chemical weapons or terrorist activities | Stop shipping and review | List misses may also trigger usage exclusions or destination/user bans. |
How to judge artificial graphite anode material
The product name "artificial graphite anode material" itself is listed in the 58 The period of account suspension cannot be directly equivalent to the current control; it must be returned to the period that is still valid.1C108Determine item by item.
| actual material | Current preliminary judgment | Parameters to be requested |
|---|---|---|
| Pure artificial graphite negative electrode powder | Usually not 1C108.b Hit, but needs to be confirmed | official FAQ It is pointed out that the powder does not have flexural strength and cannot meet the three thresholds at the same time; it is still necessary to obtain a statement of material, purity, form and that it does not contain natural flake graphite. |
| Artificial graphite blocks, plates, rods or other articles | Comparison one by one 1C108.a/b | Density, tensile breaking strain, thermal expansion coefficient, or purity, flexural strength, density. |
| Natural flake graphite, spheroidized graphite, expanded graphite | 1C108.c Permission required | Mineral sources, processing forms, composition and 2026 Reference the customs item number. |
| Artificial + natural graphite mixed negative electrode material | Cannot just reference paused 3C902.b.2 | No.58 The entry for hybrid negative electrode No. 1 is suspended; however, as long as it contains natural flake graphite or its products, item identification should be done to the Ministry of Commerce and should not be declared free for export. |
| Graphite negative electrode installed in finished battery | Determined based on finished product and actual transaction | Generally, batteries are not disassembled and assumed to be equivalent to raw materials; the battery itself, technology transfer, end use and transportation are still examined. |
2025 year 58 Full range of numbers: currently only "pause" can be displayed
The following content is the 58 The original planning control scope of No.70 The announcement is currently suspended. Reserved on the website for members to collect parameters and information in advance 2026-11-10 Review before and after, but it shall not be regarded as a valid license obligation on that day.
| Original control code | No.58 No. original column content | Currently showing |
|---|---|---|
3A001 | Weight energy density ≥300 Wh/kg Rechargeable and rechargeable lithium-ion batteries (cells and battery packs), refer to 85076000. | pause |
3B901.a | Winding machine, lamination machine, liquid injection machine, hot press, chemical and volumetric system, volumetric cabinet. | pause |
3E901.a | for production 3A001 Controlled battery technology. | pause |
3C901.a.1 | Compacted density≥2.5 g/cm ³And gram capacity ≥156 mAh/g Lithium iron phosphate cathode material. | pause |
3C901.a.2/.3 | Nickel-cobalt-manganese/nickel-cobalt-aluminum hydroxide ternary precursor and lithium-rich manganese-based cathode material. | pause |
3B901.b | Roller kiln, high-speed mixer, sand mill, jet pulverizer and other cathode material equipment. | pause |
3C901.b.1 | Artificial graphite anode material. | Pause; still checking 1C108 |
3C902.b.2 | Artificial graphite and natural graphite mixed negative electrode materials. | Suspended; Contains natural graphite, subject to inspection 1C108.c |
3B901.c | ≥5 m ³Granulating kettle, graphitization furnace,>300 L Fusion coating, >60 m ³Spray drying,>0.5 m CVD Rotary kiln and other equipment. | pause |
3E901.b | Granulation, continuous graphitization, liquid phase coating processes and technologies. | pause |
No.58 The original text of the No. requires filling in "dual-use items + control code" in the remarks column of the customs declaration form. If it is close but not included, fill in "not dual-use items + specific parameters". Indi 58 The entire number is suspended, and this exclusive reporting text cannot be regarded as the current mandatory rule for the above-mentioned suspended items; however, customs declarers must still declare truthfully in accordance with other current laws and effective controls.
Don’t miss another set of “technology export restrictions” system
| No. | Current content | Export results |
|---|---|---|
252604X | Battery cathode material preparation technology, including preparation technology of lithium iron phosphate, lithium iron manganese phosphate and phosphate cathode raw materials that comply with catalog control points. | Restrictions on export technology licenses |
083201X | Control points in non-ferrous metal metallurgical technology include lithium extraction from spodumene, preparation of metallic lithium/lithium alloys and lithium materials, lithium extraction from brine, and lithium-containing purification solutions. | Restrictions on export technology licenses |
This system governs the transfer of technology overseas and is not equivalent to an export license for dual-use items. Technology can be transferred through investment in factory construction, licensing, consulting services, remote debugging, drawings, parameter packages and personnel training. No.58 in the number 3E901 Although it is suspended, it does not mean that 252604X with 083201X Pause together.
China Customs and Dangerous Goods Packaging: What Exporters Should Do
Whether lithium batteries require a dual-use item license and whether they are dangerous goods and whether they require customs packaging inspection are two issues. For lithium batteries that are dangerous goods for export, manufacturing companies and packaging companies should go to the local customs based on the actual packaging type.
1Do the hazard and transportation classification first
Confirm lithium metal/lithium ion, transported separately or packaged with/installed in equipment, rated energy, cell status and suitability UN number.
2Packaging production enterprises apply for performance inspection
Apply for "dangerous package performance" through the international trade single window or the customs government service platform, and obtain the "Entry and Exit Goods Packaging Performance Inspection Result" after passing the test.
3Dangerous goods production enterprises apply for use appraisal
Apply for "Use of Dangerous Packages" based on actual packaging after loading, and the Customs will obtain the "Outbound Dangerous Goods Transport Packaging Usage Appraisal Result Sheet" after processing on-site.
4Submit shipping documents to carrier
UN38.3 Whether the test summary, safety data sheet, transportation condition identification, dangerous goods declaration, marking and other documents are required shall be confirmed according to the battery type, transportation method, carrier and destination rules.
Dangerous package performance inspection official listed materials
- Entry and Exit Goods Packaging Inspection Application Form
- Packaging container cycle inspection report
- Factory inspection certificate or product conformity statement of the manufacturer
- Export dangerous goods packaging sales contract
Dangerous package use identification official listing materials
- Entry and Exit Goods Packaging Inspection Application Form
- Entry and Exit Goods Packaging Performance Inspection Result Sheet
- Factory inspection qualification record sheet or product conformity statement of the manufacturer
- Classification and Identification Report of Hazardous Characteristics of Export Dangerous Goods
- Export Dangerous Goods Sales Contract
UN38.3,MSDS Or the transportation appraisal is safe transportation and carrier review data, not the Ministry of Commerce’s export license for dual-use items; conversely, obtaining a dual-use item license does not mean that shipping companies, airlines or express delivery companies will definitely carry it.
When it is determined that a dual-use item is hit, the permit application document
Chinese exporters apply through the unified platform of the Ministry of Commerce's business system; the technical indicators and end uses must be specific, and cannot just write "battery materials" and "industrial uses."
- Stamped and signed application form
- Export contract, agreement or other transaction proof
- Item technical description or test report; graphite lists actual measured values such as purity, flexural strength, density, etc.
- Original and Chinese translation of end-user and end-use certification
- Introduction to importers and end-users and Chinese translation
- Identity certificates of legal persons, main business managers and managers
- Supplementary information such as quantity rationality, measurement unit conversion, transportation route or middleman instructions, etc.
If it cannot be determined, business consultation should be made before exporting; a license must be obtained after customs clearance, and the nature of "export without permission" cannot be corrected. In principle, relevant transaction, judgment, user screening and licensing information should be kept at least 5 years.
Taiwanese members should obtain this information from the Chinese seller before placing an order.
- Complete make, model, manufacturer and product photos
- Chemical system: lithium ion, lithium metal, lithium thionite chloride or other
- Cell/battery pack,Wh,Ah,V, net weight and gravimetric energy density
- Actual filling volume of thionyl chloride single cell or battery pack
- Graphite is artificial or natural scale or mixture; powder, block or product
- Graphite purity, flexural strength, density, tensile fracture strain, thermal expansion coefficient testing data
- UN38.3 Test summary, hazard classification and shippable packaging information
- Item determination, Ministry of Commerce consultation or licensing arrangements for Chinese exporters
- True end user, end use, destination and whether it will be resold
FAQ
official source
- Announcement from the Ministry of Commerce and the General Administration of Customs 2025 year 70 No.: Suspended No.58 No. and other measures to 2026-11-10
- Announcement from the Ministry of Commerce and the General Administration of Customs 2025 year 58 No.: Control content of raw materials for lithium batteries and artificial graphite anode materials
- Announcement from the Ministry of Commerce and the General Administration of Customs 2023 year 39 No.: Export Control of Graphite Items
- 2026 Annual dual-use items and technology import and export license management catalog PDF
- China Export Control Information Network: Export License for Graphite Dual-Use Items FAQ
- China Export Control Information Network: Guidelines for filing applications for export licenses for dual-use items
- Customs Government Services: Export Dangerous Goods Packaging Performance Inspection
- Customs Government Services: Appraisal of Packaging Use of Export Dangerous Goods
- Announcement from the Ministry of Commerce and the Ministry of Science and Technology 2025 year 28 No.: Adjustment of catalog of restricted export technologies
- China Export Control Law
- Dual-use Items Export Control Regulations
This article is based on 2026-08-23 Compliance identification statements made in available official announcements do not replace the official decisions of the Chinese Ministry of Commerce, Customs, carriers or destination authorities on individual cases.
Then check these pages
Check China export status first, then packaging and Taiwan import rules
Give the Chinese exporter and carrier the model, Wh rating, chemistry, graphite composition and measured technical parameters for item-by-item review.
View Taiwan lithium-battery shipping rules