Introduction: battery sourcing now includes the end of the battery’s first life
Battery procurement is often judged on cell performance, price, delivery reliability and warranty terms. But for electric-vehicle, energy-storage and related supply chains, another question is becoming harder to ignore: what happens when a battery reaches the end of its first useful life? Collection, safe storage, transport, dismantling, material recovery and recycled-product quality all affect cost, environmental exposure and the credibility of lifecycle claims.
On September 15, 2026, China’s Ministry of Industry and Information Technology (MIIT) published a draft 2026 guide for building a standards system for the power-battery recycling and utilization industry. The draft proposes a coordinated framework covering the full chain—from collection and storage/transport to physical and chemical processing, recovered products and green/low-carbon practices—with a target of formulating or revising more than 50 national standards by 2030.
For overseas buyers, this is a useful forward-looking signal, not a new certification that every battery supplier must already hold. The practical response is to strengthen supplier due diligence now: understand where retired batteries come from, how they are handled, which legal requirements apply, how recovered materials are tested and whether environmental claims can be traced to evidence.
First, distinguish the draft roadmap from rules already in force
The 2026 standards-system guide was issued for public consultation as a draft. MIIT’s notice set the consultation period from September 16 to October 15, 2026. That period has now closed. The official notice and attached document continue to identify the text as a consultation draft; buyers should check for a later final version or implementation notice before relying on the draft as settled policy.
A standards-system roadmap is not the same as a mandatory product standard, a factory licence, an environmental permit or a certificate of conformity. Its proposed future standards may later be developed, revised, approved and implemented on different schedules. A buyer should not tell a supplier that every element of the draft is already a legal requirement, nor accept a supplier’s claim that it has a single certificate covering the entire roadmap.
China also has a separate regulatory measure already in force: the Interim Measures for the Recycling and Comprehensive Utilization of Waste Power Batteries from New Energy Vehicles, jointly issued by six ministries and commissions as Order No. 73. It took effect on April 1, 2026. It establishes responsibilities for relevant battery and vehicle producers, recovery arrangements, traceability reporting and conditions for comprehensive utilization activities within China.
The two documents must not be conflated. The draft standards guide defines power batteries broadly to include batteries supplying power to new-energy vehicles and electric bicycles, including lithium-ion and nickel-metal-hydride batteries, while excluding lead-acid batteries. Order No. 73 is specifically about waste power batteries from new-energy vehicles and related activities in China. Its obligations should not automatically be applied to every battery chemistry, product category or cross-border transaction.
What the draft proposes: six connected standards areas
1. Basic and general standards
The first area provides common foundations for the chain. The draft identifies terminology, identification and traceability, safety, occupational health and other general requirements. It aims to reduce inconsistent definitions and procedures, establish common battery and recovered-product identification, and provide consistent safety and worker-protection expectations across collection, storage, transport and processing.
For buyers, this points to the importance of a shared vocabulary and consistent records. A recycler’s use of terms such as ‘recycled material’, ‘black mass’, ‘recovered metal’ or ‘second-life battery’ should be clear enough to connect incoming battery lots, processing records and outgoing products. If different sites or subcontractors use incompatible lot identifiers, the buyer may be unable to reconstruct the chain.
2. Collection and classification standards
The draft focuses on collection requirements, collection-point arrangements, delivery and registration procedures, battery grading and classification, testing, packaging, storage, transport and collection equipment. It describes classification using factors such as remaining capacity, appearance and damage condition, so batteries with materially different risk profiles are not casually mixed.
This is commercially important. A batch of intact packs removed from vehicles is not equivalent to a mixed load of damaged, swollen, partially dismantled or unknown-origin batteries. State of health, residual energy and visible damage affect safe handling, transport planning, processing yield and the reliability of any later material-quality claim.
3. Physical-processing standards
The physical-processing area covers removal, dismantling, crushing, separation and related equipment. The draft refers to dismantling sequence and methods, discharge and short-circuit prevention, worker qualifications, crushing and grinding, separation precision, operating environments and equipment protection, installation and maintenance.
Buyers engaging a recycler should understand how it isolates energy, prevents short circuits, controls fire risk and separates battery components before chemical treatment. A facility photograph showing a shredder is not proof of a safe, controlled process. The buyer needs to understand the actual process route, equipment configuration, site controls and the materials produced at each stage.
4. Chemical-processing standards
The chemical-processing area addresses key resource-recovery processes, including pyrometallurgical and hydrometallurgical methods, purification, synthesis and the facilities and equipment used. The draft discusses process parameters, impurity removal, synthesis of regenerated cathode and anode materials, and control of lithium, cobalt and nickel recovery.
Different chemistries and process routes produce different intermediate materials and require different controls. A buyer should not assume that every recycler can process every chemistry or that a single stated recovery rate applies to all incoming lots. Process capability, feedstock acceptance limits, reagent management, emissions controls and product specifications need to be examined together.
5. Comprehensive-utilization product standards
This area focuses on intermediate materials and recovered products, including black mass, regenerated metal salts, precursors and regenerated cathode and anode materials. The draft identifies quality characteristics such as purity, particle size and the proportion of recovered elements.
For a downstream buyer, the important question is whether a recovered material consistently meets the technical specification of the next manufacturing process. A high headline recovery rate does not by itself prove battery-grade quality. Request test methods, batch results, impurity limits, sampling rules and evidence that the material performs in the intended application.
6. Green and low-carbon standards
The sixth area includes green design, energy saving and carbon reduction, analysis and testing, management evaluation, verification and accounting, and treatment of solid waste, wastewater and exhaust gas. It links lifecycle considerations with environmental performance and the verification of claims.
This matters when a supplier markets recycled content, lower-carbon materials or circularity benefits. Buyers need to know what is included in the calculation, which process stages and energy sources are counted, how recycled input is allocated, and whether the data can be independently checked. A broad ‘green battery’ statement is not a substitute for a defined methodology and auditable evidence.
Why this roadmap matters to overseas buyers
First, it makes the battery end-of-life chain more visible. Buyers who previously focused on cell factories may need to understand collection partners, logistics providers, dismantlers, processors and material refiners. The party signing a sales contract may not operate every stage itself.
Second, it raises the value of traceability. If a recovered material cannot be linked to an incoming battery lot, the buyer may struggle to assess source legitimacy, process history, environmental risk or the validity of recycled-content claims.
Third, it can affect future procurement specifications. As standards are developed, buyers may see more detailed requirements for classification, transport, safety, process controls, recovered-material quality and carbon accounting. Early supplier engagement can reduce the cost of adapting later.
Fourth, end-of-life management can become a supply-continuity issue. Recovered lithium, nickel, cobalt and other materials may form part of a procurement strategy, but only if the quality, volumes, origin and legal handling are sufficiently reliable.
A practical supplier-verification checklist
1. Define the battery and transaction scope
Record the battery chemistry, product type, original application, manufacturer, model, pack/module/cell form, condition and intended end use. Clarify whether the material is a retired new-energy-vehicle battery, an electric-bicycle battery, production scrap, a defective product or another category. Do not assume the same rules apply to all of them.
Confirm whether the activity takes place in mainland China, involves cross-border movement, or concerns material already processed into a recovered product. The applicable requirements may differ by jurisdiction, waste classification, chemistry, condition and transaction stage. Obtain specialist regulatory advice for cross-border shipments or hazardous-waste questions.
2. Verify the legal identity and role of every key party
Identify the battery producer, vehicle producer where relevant, collection operator, transporter, dismantler, recycler and recovered-material seller. Establish which entity actually performs each activity and which entity is contractually responsible. If the supplier is a trading company, request the names and roles of the actual operating facilities and subcontractors.
Where Order No. 73 applies to waste power batteries from new-energy vehicles in China, check how the responsible battery or vehicle producer fulfils its recovery obligations and how the batteries reach an appropriately established comprehensive-utilization enterprise or recovery service network. Do not assume a broker’s invoice proves that the underlying route is lawful.
3. Check traceability from source to output
Request sample records showing battery identification codes, source organization, incoming date, quantity, chemistry, condition, storage location, processing batch and destination of outputs. Compare the identifiers across weighbridge records, inventory logs, processing records, invoices and shipment documents.
Ask how damaged or unidentified batteries are handled, how records are corrected, who can amend them and how long they are retained. Under Order No. 73, specified entities must report defined battery and flow information through the national information platform. Confirm the precise reporting obligation for the party and transaction rather than assuming every overseas buyer has direct access to the platform.
4. Examine collection and classification controls
Review collection-point arrangements, acceptance criteria, inspection procedures, state-of-health or residual-energy testing where relevant, visual-damage classification and segregation rules. Ask for examples of how the facility handles intact, damaged, swollen, leaking or otherwise abnormal batteries.
Check whether the supplier has documented criteria for rejecting unsuitable loads and whether it can trace rejected material. Inconsistent grading can distort commercial settlement, processing yields and safety risk.
5. Verify packaging, storage and transport
Request the procedures and records relevant to the battery type and condition: packaging specification, terminal protection, segregation, storage layout, fire prevention, emergency response, loading controls, transporter qualifications and route planning. Confirm which party is responsible for classification and transport documentation.
Do not treat a general dangerous-goods statement as proof that a specific shipment is correctly classified and packaged. Damaged batteries may require different handling from intact batteries. For cross-border movements, separately verify applicable export, import, customs, waste and dangerous-goods rules in every relevant jurisdiction.
6. Audit physical-processing capability
At the facility, follow a representative lot from receipt to discharge, dismantling, crushing and separation. Check equipment maintenance, isolation procedures, short-circuit prevention, fire detection and suppression, ventilation, worker training, personal protective equipment and management of residual materials.
Ask for process-flow diagrams, operating procedures, equipment lists, maintenance records, incident logs and recent corrective actions. Match the evidence to the chemistry and pack design the facility actually receives. A generic site tour is not enough if the supplier outsources key processing stages.
7. Review chemical-processing and environmental controls
For facilities using pyrometallurgical or hydrometallurgical routes, request process descriptions, feedstock acceptance limits, reagent controls, pollution-control equipment, monitoring records and waste-treatment procedures. Review how the facility manages wastewater, exhaust gas, solid residues and any hazardous by-products.
Order No. 73 states that comprehensive-utilization activities in China require the relevant project approval or filing, completion of environmental-impact assessment, construction of supporting environmental-protection and safety facilities, and a pollutant-discharge permit or registration as applicable. Request the documents relevant to the actual site and activity, and check that the legal entity, address, scope and operating status match.
8. Verify recovered-material quality
Ask for product specifications and representative batch reports for black mass, metal salts, precursors or regenerated active materials. Confirm the test method, sampling plan, laboratory, batch identifier, date, measured impurities, moisture or other relevant characteristics, and acceptance criteria.
If the material is intended for battery manufacturing, request evidence that the buyer’s downstream process accepts the specification. A recycler’s internal certificate or a single sample report does not establish consistent quality across different feedstocks and production lots.
9. Test environmental and recycled-content claims
Ask for the calculation boundary, allocation method, input/output mass balance, energy data, recycled-content methodology and supporting records. Determine whether the claim relates to a particular batch, production period, site or company-wide average.
Where the supplier claims lower carbon emissions, compare the stated baseline, energy mix, transport assumptions, process route and treatment of co-products. Independent verification can be useful, but the verifier’s scope and assurance level must match the claim being made.
10. Confirm capacity, subcontracting and continuity
Review actual throughput, permitted or approved scope, operating shifts, equipment bottlenecks, feedstock dependence, inventory practices and major subcontractors. Ask what happens when a processing line is down or a source of battery feedstock becomes unavailable.
Compare claimed capacity with observed equipment, recent production records and outgoing shipment volumes. Materially inconsistent figures, unexplained subcontracting or inability to trace output to input lots should trigger further review.
What Order No. 73 adds to the current compliance baseline
The draft standards guide describes a future standards architecture. For waste power batteries from new-energy vehicles handled within China, Order No. 73 already sets out several concrete management responsibilities. These include battery coding and durable identification, provision of necessary dismantling information, producer recovery responsibilities and publication of recovery-service information.
The measures also establish responsibilities for routing collected batteries to legally established comprehensive-utilization enterprises, subject to the stated provisions. Such utilization activities must meet applicable resource-utilization, environmental-protection and work-safety requirements. Relevant project procedures, environmental assessment, facilities and discharge permits or registrations must be in place before the covered activities are undertaken.
Order No. 73 also establishes information-reporting duties for specified parties and time limits for reporting different events, including production/import, sales, replacement, collection, warehousing and dispatch information. Buyers should identify which party bears each reporting duty and ask for evidence that the required records are maintained.
One important restriction is that waste power batteries covered by Order No. 73 must not be used directly or after processing in electric bicycles or other fields prohibited by laws, regulations or mandatory standards. Buyers considering second-life or repurposing projects should not assume that a battery can be moved into another product category simply because it passes a basic electrical test.
These requirements apply within the defined scope of the measure. They should not be generalized to every battery, every recycling activity worldwide or every cross-border movement. The draft guide’s broader definition and the binding measure’s scope are not identical.
Contract clauses worth agreeing before a purchase or recycling engagement
Define the feedstock precisely: chemistry, product type, condition, source, acceptable contamination, documentation and rejection criteria.
Allocate responsibility for title and custody at each handover, including rejected loads, damaged batteries, transport incidents and storage during disputes.
Specify traceability records, battery identifiers, batch reconciliation, record retention, audit access and notification of any data discrepancy.
Identify every material subcontractor and facility. Require prior notice and approval for changes to collection, transport, dismantling or chemical-processing sites.
Set measurable recovered-product specifications, sampling procedures, independent testing rights, retest rules and remedies for out-of-specification material.
Require evidence of permits, environmental procedures and safety controls applicable to the contracted activity, with prompt notice of suspension, expiry or enforcement action.
Define environmental and recycled-content claims by methodology, boundary, period, product and verification evidence. Prohibit unsupported or misleading claims.
Agree incident notification, corrective action, recall cooperation, insurance, liability allocation and business-continuity arrangements.
Warning signs that deserve follow-up
A supplier cannot identify the actual collection or processing site, or repeatedly changes the named facility without explanation.
Battery origin, serial/code records, weights or lot identifiers do not reconcile between incoming and outgoing records.
The supplier cannot explain how damaged batteries are segregated, stored, transported or made safe before processing.
Environmental permits or project documents name a different entity, address or activity from the site being offered for inspection.
Recovered-material reports lack a batch link, test method, sampling details or identifiable issuing laboratory.
Claims of universal chemistry capability, very high recovery rates or carbon savings are presented without process-specific data.
An intermediary refuses to disclose key subcontractors while asking the buyer to accept full traceability or compliance claims.
Limitations and uncertainty
The MIIT standards-system guide discussed here was a consultation draft with a public comment period ending October 15, 2026. Its 2030 target and six-part structure are proposals in that draft, not a statement that more than 50 new standards have already been issued or that every proposed requirement is currently mandatory. Verify the final guide and subsequent individual standards when they are published.
Order No. 73 is a separate measure already in force from April 1, 2026, but it concerns waste power batteries from new-energy vehicles and related activities in China. Its provisions should be applied only after checking the transaction, entity and battery fall within its scope. The draft guide includes a broader battery definition and expressly excludes lead-acid batteries; other battery categories may be governed by separate waste, hazardous-material, product-safety or environmental rules.
This article is a buyer-oriented due-diligence guide, not legal advice, a technical conformity assessment or an audit of any named recycler. The actual requirements depend on chemistry, battery condition, activity, location and destination market. Obtain qualified local advice before moving used batteries or waste materials across borders.
Conclusion
China’s proposed power-battery recycling standards roadmap signals a move toward more connected controls over the battery lifecycle. For overseas buyers, the opportunity is to prepare before the standards mature: verify the source and identity of batteries, follow the chain through collection and processing, assess safety and environmental controls, and demand batch-level evidence for recovered materials and lifecycle claims.
The strongest supplier assessment does not stop at a certificate or a recycling-rate headline. It connects the legal entity, facility, battery lot, process route, output specification and environmental evidence into one traceable record. That is the foundation for a more resilient and credible battery supply chain.
Sources / Research Notes
1. Ministry of Industry and Information Technology (MIIT), Department of Science and Technology, public consultation notice dated September 15, 2026: Draft Guidelines for Building a Standards System for the Power-Battery Recycling and Utilization Industry (2026 Edition). Consultation period: September 16–October 15, 2026. https://www.miit.gov.cn/jgsj/kjs/jscx/bzgf/art/2026/art_4c8055c61f234cff8c100574c1ab709b.html
2. MIIT, attached nine-page consultation draft, Guidelines for Building a Standards System for the Power-Battery Recycling and Utilization Industry (2026 Edition). Contains the scope definition, 2030 target of more than 50 national standards, six-part structure and detailed proposed work areas. https://www.miit.gov.cn/cms_files/filemanager/1226211233/attach/20269/c335852d7850494daff9a9248c5e245f.pdf
3. Order No. 73 of six Chinese ministries and commissions, Interim Measures for the Recycling and Comprehensive Utilization of Waste Power Batteries from New Energy Vehicles, published December 31, 2025 and effective April 1, 2026; official government text reproduced by the Ministry of Commerce on May 6, 2026. https://www.mofcom.gov.cn/zcfb/zgdwjjmywg/art/2026/art_ff7443a616d74bb18c8d71806bd45ab5.html
4. Xinhua News Agency, September 15, 2026, reporting on the draft guide’s target of more than 50 national standards by 2030 and its full-chain, six-part structure. https://www.eeo.com.cn/2026/0915/1037123.shtml
Research Notes: The draft defines power batteries as batteries providing power to new-energy vehicles and electric bicycles, including lithium-ion and nickel-metal-hydride types, and excludes lead-acid batteries. The consultation deadline has passed. The article distinguishes the proposed standards roadmap from binding Order No. 73 and avoids treating the draft as a current certification regime.
Internal traceability
Research ID: SCC-RES-2026-044
Story ID: SCC-INS-2026-031
