China Launches Joint Enforcement on Used EV Battery Recycling

On April 28, 2026, China’s Ministry of Industry and Information Technology (MIIT) and four other departments jointly issued a notice launching a nationwide joint enforcement campaign targeting the recycling and reuse of spent lithium-ion traction batteries. The action—effective from May 2026—directly affects international importers of Chinese-made electric equipment, including construction machinery, two-wheelers, and energy storage systems, by tightening compliance requirements under extended producer responsibility (EPR) frameworks.

Event Overview

On April 28, 2026, MIIT, the Ministry of Ecology and Environment, the Ministry of Commerce, the General Administration of Customs, and the State Administration for Market Regulation jointly released the Notice on Launching a Special Joint Enforcement Campaign to Regulate the Recycling and Utilization of Spent Power Batteries. Starting in May 2026, authorities will conduct coordinated inspections across provinces focusing on three categories of entities: battery export enterprises, remanufacturers, and cross-border battery recycling service providers. Verification will cover traceability registration compliance, dismantling qualifications, and environmental protection standards.

Industries Affected

Direct Trading Enterprises

Importers and distributors of Chinese-origin electric equipment containing lithium-ion batteries—including electric forklifts, e-scooters, and modular battery energy storage systems—are now required to validate their Chinese suppliers’ official recycling registration status and green supply chain certification before customs clearance. Non-compliant suppliers may face shipment delays or rejection at destination ports where EPR reporting is mandatory.

Raw Material Procurement Enterprises

Firms sourcing cathode active materials, black mass, or recovered cobalt/nickel from Chinese recyclers must confirm whether those recyclers are included in the national traceability platform’s approved list. Unregistered processors may not legally issue compliant material declarations, affecting downstream due diligence for EU Battery Regulation (EU 2023/1542) or U.S. Inflation Reduction Act (IRA) critical mineral sourcing requirements.

Manufacturing Enterprises

OEMs and ODMs assembling battery-integrated products in China—especially those exporting to markets with EPR schemes—must ensure their battery suppliers maintain valid recycling备案 (filing) and provide auditable chain-of-custody records. Absence of such documentation may compromise product-level EPR registration in importing countries, limiting market access.

Supply Chain Service Providers

Third-party logistics firms, customs brokers, and certification bodies supporting cross-border battery movement must now verify whether consignments include evidence of upstream recycling compliance—such as platform-generated traceability codes or Ministry-issued qualification certificates—when preparing documentation for export or transit.

Key Focus Areas and Recommended Actions for Stakeholders

Monitor Official Guidance and Implementation Timelines

Stakeholders should track updates from MIIT’s National Traceability Management Platform for Power Batteries and provincial industry bureaus, particularly regarding the rollout schedule for mandatory registration deadlines, eligibility criteria for recycling service providers, and technical specifications for traceability data submission.

Verify Supplier Compliance Status for Priority Export Categories

Importers and OEMs should prioritize verification for high-volume, high-risk categories: electric two-wheelers (e-bikes/e-scooters), off-road electric construction equipment, and containerized stationary storage systems—products most likely subject to early scrutiny under the enforcement campaign.

Distinguish Between Policy Signal and Operational Requirement

The notice signals a formalization of enforcement capacity—not an immediate expansion of regulatory scope. Current obligations remain anchored in existing rules (e.g., Administrative Measures for Traceability Management of Power Batteries, 2021), but the joint operation indicates heightened inter-agency coordination and audit frequency, especially for export-oriented entities.

Prepare Documentation and Communication Protocols Now

Companies should request updated recycling filing certificates and traceability platform access credentials from Chinese battery suppliers; integrate these into procurement checklists; and align internal compliance teams with customs brokers to pre-validate documentation packages ahead of May 2026 shipments.

Editorial Perspective / Industry Observation

Observably, this joint enforcement initiative functions primarily as a signal of institutional readiness—not yet a fully scaled regulatory outcome. It reflects China’s intent to strengthen domestic implementation of its battery circular economy framework, particularly in anticipation of stricter global EPR alignment. Analysis shows that while the notice does not introduce new legal obligations, it significantly raises the operational cost of non-compliance for exporters and their foreign partners. From an industry perspective, the campaign underscores how domestic regulatory execution in China increasingly shapes upstream compliance expectations for global supply chains—even where no new international treaty or standard is involved.

Concluding, this development marks a procedural escalation in China’s battery sustainability governance rather than a substantive policy shift. It is best understood not as an isolated enforcement measure, but as an indicator of growing integration between China’s domestic traceability infrastructure and international product stewardship expectations. For stakeholders, the current priority is verification—not revision—of existing supplier engagement protocols.

Source: Joint Notice issued by MIIT, Ministry of Ecology and Environment, Ministry of Commerce, General Administration of Customs, and State Administration for Market Regulation, published April 28, 2026.
Additional monitoring is advised for provincial implementation guidelines, which have not yet been publicly released and remain subject to further clarification.