China has announced a regulatory adjustment to streamline the import and export management of lithium thionyl chloride (LTC) batteries, easing compliance requirements for low-risk products while maintaining oversight through customs declarations.
The update was jointly issued by the Ministry of Industry and Information Technology (MIIT), the Ministry of Commerce (MOFCOM), and the General Administration of Customs (GACC), reflecting China’s ongoing efforts to balance trade facilitation with chemical safety and export control objectives.
Scope of the New Regulation
The revised rules apply to:
- Lithium thionyl chloride batteries or battery packs containing no more than 1 kg of thionyl chloride per unit
These batteries are widely used in industrial electronics, metering devices, and other specialized applications.
Regulatory Changes
Removal from Chemical Monitoring and Export Control Lists
Effective 1 January 2026, eligible LTC batteries will:
- No longer be classified as monitored chemical articles
- Be removed from dual-use export control management
Consequently, companies exporting or importing qualifying products will no longer need to apply for monitoring chemical approvals or dual-use export licenses.
Continued Customs Declaration Obligations
Despite the relaxation of licensing requirements, exporters must:
- Truthfully declare the actual thionyl chloride content of LTC batteries during customs clearance
This requirement ensures transparency and supports risk-based customs supervision.
Products Still Subject to Control
The regulatory adjustment does not apply to:
- LTC batteries exceeding the specified chemical content threshold
- Products covered by other chemical control or export restriction regimes
Such products must continue to comply with existing approval and licensing procedures.
Impact on Businesses
For Manufacturers and Exporters
- Reduced regulatory burden for qualifying products
- Faster and more efficient customs clearance
- Continued responsibility for accurate product declarations
For Compliance Teams
- Review product specifications to confirm eligibility
- Update internal compliance and customs documentation systems
- Monitor further developments in China’s chemical management framework
China’s latest policy update marks a significant step toward simplified trade management for lithium thionyl chloride batteries. By removing low-risk products from strict monitoring requirements while retaining essential declaration obligations, the authorities aim to support industrial supply chains without compromising safety or regulatory oversight.
The new measures will come into force on 1 January 2026, and companies engaged in battery manufacturing or trade should prepare accordingly.
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