Lithium-Ion Recycling and the Export Regulations That Control it
Black mass, borders, and the battle for the battery metal supply chain
The growing importance of battery metals, lithium in particular, is no longer confined to the electric vehicle sector. Large-scale grid storage for a country’s power infrastructure and, more recently, the electricity demands of AI have made lithium-ion supply chains a matter of strategic importance. As hyperscalers such as Amazon, Google, and Meta deploy battery storage as part of a bring-your-own-capacity strategy to accelerate data center launches, interest in lithium-ion batteries and how they are disposed of has expanded well beyond the industry and into the general public.
That interest has produced a steady stream of articles on the subject. Most focus on novel recycling processes, the majority of which are rebranded versions of methods already in commercial use, or bench-scale systems not far removed from a whiteboard. What almost none of them do is examine the regulatory frameworks that actually govern how recycled lithium-ion material moves across borders, how it is classified under international law, and what that means for where recycled material can and cannot go.
A article from Recycling Today illustrates the problem clearly. The article focuses on a Malaysian-based lithium-ion recycler and its positioning to take advantage of recent changes to China’s black mass import policies. It is not, on its face, an article about a recycling process, but it shares the same fundamental flaw: it contains nothing about the regulations that govern the trade it describes. The result is a narrative that is, in at least one key respect, technically false. Understanding why requires starting with the regulations themselves.
What is Black Mass
Black mass is an intermediate produced during the second stage of lithium-ion recycling, after initial cell collection. In this stage, cells are processed into what is essentially a highly refined ore. Its precise composition varies depending on the platform used. The percentage of valuable metals recovered, the impurity profile, and the physical characteristics all differ from one commercial platform to another.
One impurity of particular concern is fluoride, which can arise from the breakdown of lithium hexafluorophosphate (LiPF6), a common battery electrolyte salt. Fluoride can corrode equipment, impede the recovery of valuable metals such as lithium, cobalt, and nickel, and require additional treatment steps that increase processing cost and complexity.
China’s Import Policy Changes
China updated its black mass import policy in 2025. The announcement was issued jointly by six ministries and agencies, including the Ministry of Ecology and Environment and the General Administration of Customs, and established that qualified black mass would no longer be classified as solid waste and could be imported freely, provided it meets strict specifications.
For Category 1 NMC and LCO chemistries, those requirements include a minimum combined nickel and cobalt content of 25%, a minimum lithium content of 3.5%, and a water-soluble fluoride limit of 0.4%. The fluoride limit is the most consequential of these criteria for international suppliers. While framed publicly as an environmental measure, it is a direct response to the processing problems fluoride creates for Chinese refiners: the same corrosion, yield suppression, and additional treatment costs described above.
Side Note: Since the specifications include a minimum lithium content threshold, black mass produced by at least two cradle-to-gate recyclers in the United States, Ascend Elements and American Battery Technology Company, would be immediately disqualified for Chinese import. Both use an early-stage lithium recovery process that results in a black mass with only trace amounts of lithium remaining, putting them well below the 3.5% minimum required under Category 1 NMC and LCO criteria.
The Recycling Today article is a product of the interest these changes have generated. The Malaysian recycler profiled is positioning itself as a midstream processor, taking in black mass from various sources, upgrading it to meet Chinese import standards, and routing it into the Chinese market. The article suggests that European black mass could be part of that feedstock supply.
That is where the absence of any regulatory context becomes a problem.