China Optimises Import-Export Rules for Lithium Batteries

China has announced updated import and export supervision measures for lithium sulphuryl chloride batteries, easing regulatory requirements for specific low-risk products while maintaining chemical safety oversight.

The measures were jointly issued by the Ministry of Industry and Information Technology (MIIT), the Ministry of Commerce (MOFCOM), and the General Administration of Customs on 12 December 2025, and will come into force on 1 January 2026.

Regulatory Basis and Policy Objective

The update is outlined in the official “Notice on Optimising the Import and Export Supervision Measures for Lithium Sulphuryl Chloride Batteries.” It refines the application of controls under:

• Regulations on the Supervision and Control of Monitoring Chemical Products
• Export Control List of Dual-Use Items and Technologies

The objective is to reduce unnecessary administrative burdens while ensuring national security, chemical safety, and effective customs supervision.

Batteries Covered Under the Updated Measures

The revised rules apply to lithium sulphuryl chloride batteries or battery packs that meet all the following conditions:

• Contain sulphuryl chloride (CAS No. 7719-09-7)
• Have a filling quantity of no more than 1 kg per unit
• Are classified under the third category of monitored chemical products

This targeted scope reflects the relatively lower risk profile of small-capacity battery products.

Regulatory Changes

Removal from Monitoring Chemical and Dual-Use Controls

Under the new notice, qualifying lithium sulphuryl chloride batteries are excluded from monitoring chemical and dual-use export controls. As a result:

• Import approval for monitoring chemical products is no longer required
• Dual-use export licensing is no longer applicable

This change simplifies cross-border trade procedures for eligible products.

Continued Customs Declaration Requirements

Although licensing requirements are relaxed, companies must still comply with customs declaration obligations. Importers and exporters are required to accurately declare:

• Battery type, model, and technical specifications
• The sulphuryl chloride content contained in each unit

Truthful and complete declarations remain essential for regulatory transparency and enforcement.

Products Remaining Under Control

The notice clarifies that:

• Lithium sulphuryl chloride batteries not meeting the specified conditions remain subject to existing monitoring chemical and export control rules
• Products governed by other applicable laws or regulatory regimes must continue to comply with those requirements

The exemption applies strictly to the defined product category.

Implementation and Regulatory Oversight

Chinese authorities will monitor the implementation of the new measures and may adjust supervision practices based on enforcement outcomes and industry feedback. Official consultation channels remain available through MIIT, MOFCOM, and the General Administration of Customs.

Implications for Industry

For manufacturers, importers, and exporters, the updated policy:

• Reduces regulatory complexity for compliant battery products
• Clarifies the regulatory status of batteries containing sulphuryl chloride (CAS 7719-09-7)
• Reinforces the importance of accurate customs declarations despite eased licensing requirements

Companies involved in chemical battery trade should assess product specifications in advance of 1 January 2026 to confirm eligibility under the new rules.

Source: China Eases Battery Controls