Introduction: The Golden Age and Hidden Challenges of Battery Export Customs Clearance

In the wave of the global new energy revolution, China’s lithium battery industry is ushering in unprecedented development opportunities. In 2024, China’s total lithium battery production reached 1170 GWh, a year-on-year increase of 24%. Six Chinese power battery companies ranked among the top ten in the world, and CATL ranked first globally with a market share of 37.9%. However, as the industry scale continues to expand, Battery Export Customs Clearance are also facing increasingly stringent regulatory challenges.

On October 9, 2025, the Ministry of Commerce and the General Administration of Customs jointly issued a notice, including high-performance lithium batteries and artificial graphite anode materials in the export control list. The introduction of this policy marks that China’s lithium battery exports have entered a new era of compliance. For many lithium battery export enterprises, how to choose the appropriate customs clearance method in the complex regulatory environment has become a key issue related to the survival and development of enterprises.

I. Two Typical Scenarios of Lithium Battery Exports

(A) Lithium Batteries with Complete Documentation: A Model of Compliance Exports

Lithium batteries with complete documentation refer to lithium battery products that have complete safety test reports, packaging certificates and trade documents. These documents include UN38.3 test reports, MSDS (Material Safety Data Sheet), dangerous goods packaging certificates, etc., which are necessary conditions for lithium batteries to be exported through formal channels.

The UN38.3 test report is the “safety pass” for lithium battery exports. It covers various safety performance tests of lithium batteries under extreme conditions that may be encountered during transportation, such as altitude simulation, thermal testing, vibration testing, impact testing, etc. Only lithium batteries that pass the UN38.3 test can prove that they meet international transportation safety standards and be recognized by customs around the world.

MSDS is the “safety manual” for lithium batteries. It details the composition, hazard characteristics, emergency handling methods and other information of lithium batteries, providing important reference for customs and transportation links. The dangerous goods packaging certificate is a document proving that the lithium battery packaging meets the dangerous goods transportation standards, ensuring that lithium batteries will not leak, explode or other safety accidents during transportation.

(B) Lithium Batteries with Incomplete Documentation: Dilemma in the Gray Zone

Corresponding to lithium batteries with complete documentation are lithium batteries with incomplete documentation, which refer to lithium battery products that lack necessary safety test reports or packaging certificates. These products are usually produced by some small enterprises or workshop-style factories. Due to the inability to bear the compliance costs such as UN38.3 testing, or insufficient understanding of export control policies, the documents are missing.

Lithium batteries with incomplete documentation can only be exported through gray customs clearance, which not only violates customs regulations, but also brings huge risks to enterprises. Once detected by customs, enterprises may face consequences such as cargo detention, fines or even criminal penalties.

II. Comparison of Operation Processes of Two Customs Clearance Methods

(A) DG Formal Declaration and Clearance: Standard Process for Compliance Exports

DG formal declaration and clearance is the standard process for compliance exports of lithium batteries. It requires enterprises to provide complete safety test reports, packaging certificates and trade documents, and conduct declaration and inspection in accordance with the procedures specified by customs.

1. Preparatory Stage

Before conducting DG formal declaration and clearance, enterprises need to prepare a series of documents and materials, including:

• Safety test documents: UN38.3 test report, MSDS, cargo transportation condition appraisal certificate, etc.
• Packaging and transportation certificates: dangerous goods packaging certificate, dangerous goods packaging use appraisal result sheet, etc.
• Basic trade documents: contract, invoice, packing list, export license (if applicable), etc.
• Other supplementary documents: certificate of origin, brand authorization letter, etc.

These documents are the basis for enterprises to conduct DG formal declaration and clearance. Only by ensuring the authenticity and completeness of the documents can they successfully pass the customs audit.

2. Detailed Customs Clearance Process

The process of DG formal declaration and clearance mainly includes declaration link, customs inspection, tax payment and release.

Declaration link: Enterprises need to submit the customs declaration form and relevant materials through the “single window”, and the customs system will automatically verify the consistency of the documents. During the declaration process, enterprises need to accurately fill in the commodity code, quantity, value and other information of lithium batteries, so that customs can classify and calculate taxes.

Customs inspection: Customs will inspect the declared lithium batteries, mainly including packaging and label inspection, cargo and document verification, authenticity verification of safety test reports and other contents. If problems such as unclear packaging labels, expired test reports or inconsistent cargo with declaration are found, enterprises need to rectify or supplement materials and re-declare.

Tax payment and release: After passing the customs inspection, enterprises need to pay the tariff and value-added tax calculated by customs. After payment is completed, customs will issue a “Release Notice”, and enterprises can arrange cargo shipment with this notice.

3. Transportation Requirements

Lithium batteries are dangerous goods, and their transportation links also have strict requirements. During transportation, enterprises need to ensure that the packaging of lithium batteries meets international standards, use insulating materials to isolate lithium batteries to avoid short circuits and collisions. At the same time, enterprises also need to choose transportation companies with dangerous goods transportation qualifications and transport in accordance with the specified transportation routes and methods.

(B) Undeclared Gray Customs Clearance: Risks and Costs

Undeclared gray customs clearance is a customs clearance method that violates customs regulations. It usually bypasses the normal customs clearance process through means such as under-declaring the value of goods, mis-declaring the name of goods, and forging documents, allowing goods to “enter the country illegally”.

1. Common Means of Gray Customs Clearance

• Under-declaring the value of goods: Enterprises deliberately reduce the declared price to reduce tariff expenditures. This behavior not only violates customs regulations, but also leads to the loss of national tax revenue.
• Mis-declaring the name of goods: Enterprises disguise lithium batteries as ordinary goods, such as electronic products, toys, etc., to evade customs supervision. This behavior not only brings safety hazards to the transportation link, but also threatens the life and property safety of consumers.
• Forging documents: Enterprises use false test reports, packaging certificates and other documents to deceive customs. Once discovered, enterprises will face severe penalties.
• Taking advantage of policy loopholes: Some enterprises use policy loopholes in some countries or regions to conduct customs clearance through special channels or relationships. Although this behavior may bring certain benefits in the short term, it will bring huge risks to enterprises in the long run.

2. Operation Process of Gray Customs Clearance

The operation process of gray customs clearance is usually relatively simple. Enterprises only need to hand over the goods to a freight forwarder that claims to be able to “guarantee customs clearance”, pay a certain fee, and the freight forwarder will be responsible for delivering the goods to the destination. However, behind this seemingly simple operation process, there are huge risks hidden.

III. Analysis of Applicable Scenarios of Two Customs Clearance Methods

(A) Applicable Scenarios of DG Formal Declaration and Clearance

DG formal declaration and clearance is applicable to most lithium battery export scenarios, especially for high-value goods, long-term cooperative customers and markets with strict compliance requirements.

• High-value goods: Such as new energy vehicle power batteries, large-scale energy storage system battery packs, etc. These goods have high value, and once problems occur, enterprises will face huge economic losses. Through DG formal declaration and clearance, enterprises can ensure the safe transportation of goods and reduce risks.
• Long-term cooperative customers: For customers who have long-term cooperative relationships with enterprises, they pay more attention to the quality and compliance of goods. Through DG formal declaration and clearance, enterprises can demonstrate their compliance capabilities to customers and enhance customer trust.
• Markets with strict compliance requirements: Such as the European Union, the United States and other regions that have strict standards for lithium battery imports. These regions have high regulations on the safety performance and environmental protection requirements of lithium batteries. Through DG formal declaration and clearance, enterprises can ensure that goods meet local regulatory requirements and enter the market smoothly.

(B) Applicable Scenarios of Gray Customs Clearance (Not Recommended)

Although gray customs clearance may bring certain conveniences to enterprises in some cases, it is not a sustainable customs clearance method. Generally speaking, gray customs clearance is applicable to the following scenarios:

• Small-batch samples: A small number of lithium battery products used for testing or display. Due to the small quantity and low value, enterprises may choose to export through gray customs clearance. However, even for small-batch samples, enterprises should abide by customs regulations and choose compliant customs clearance methods.
• Low-value goods: Such as small consumer electronic product supporting batteries, etc. These goods have low value, and enterprises may think that they can reduce costs through gray customs clearance. However, the risks brought by gray customs clearance far outweigh the benefits, and enterprises should choose carefully.
• Urgent delivery needs: When the formal customs clearance process cannot meet the time requirements, enterprises may choose to export through gray customs clearance. However, this approach not only violates customs regulations, but also brings huge risks to enterprises. Enterprises should plan their export plans in advance to avoid urgent delivery situations.

IV. Comparison of Cost Structures of Two Customs Clearance Methods

(A) Cost Structure of DG Formal Declaration and Clearance

The cost of DG formal declaration and clearance mainly includes direct costs and indirect costs.

1. Direct Costs

• Compliance costs: Including the handling fees of UN38.3 test reports, MSDS, dangerous goods packaging certificates and other documents, which usually range from 1000 to 2000 yuan.
• Transportation costs: Due to the fact that lithium batteries are dangerous goods, their transportation costs are relatively high. Mainly including DG cabin surcharge, dangerous goods declaration fee, packaging reinforcement fee, etc. These costs are usually 20% to 30% higher than the transportation costs of ordinary goods.
• Tariffs and value-added tax: Calculated according to the HS code and declared price of the goods. The tariff rate is usually between 0% and 15%, and the value-added tax rate is 13%.

2. Indirect Costs

• Time cost: The process of DG formal declaration and clearance is relatively complex, and it takes a certain amount of time for document preparation, declaration and inspection. It usually takes 3 to 7 working days.
• Management cost: Enterprises need to equip a professional team to be responsible for the compliance affairs of lithium battery exports, including document preparation, declaration, communication with customs and other work, which will increase the management cost of enterprises.
• Insurance cost: In order to reduce risks during transportation, enterprises usually need to purchase dangerous goods transportation insurance, and the insurance rate is about 0.3% to 0.5% of the value of the goods.

(B) Cost Structure of Gray Customs Clearance

The cost of gray customs clearance mainly includes surface costs and hidden costs.

1. Surface Costs

• Packaged fees: Including one-time fees for transportation, customs clearance, tariffs, etc., which are usually collected by freight forwarders.
• Agent fees: Fees charged by freight forwarders for providing gray customs clearance services to enterprises.

2. Hidden Costs

• Fine risk: Once detected by customs, enterprises may face fines several times the value of the goods, and the fine amount may reach tens of thousands or even hundreds of thousands of yuan.
• Cargo detention risk: Goods may be detained or confiscated by customs, and enterprises will face huge economic losses.
• Enterprise credit loss: Being included in the customs “blacklist”, the credit rating of enterprises will be affected, and future import and export business will also be restricted.
• Supply chain disruption risk: Customs clearance delays may lead to delivery delays, affecting the cooperative relationship between enterprises and customers, and even leading to supply chain disruption.

V. Risk Analysis of Two Customs Clearance Methods

(A) Main Risks of DG Formal Declaration and Clearance

Although DG formal declaration and clearance is a compliant customs clearance method, it also has certain risks.

• Policy change risk: Export control policies may be adjusted at any time, and enterprises need to pay attention to policy changes in a timely manner to ensure that their export behaviors comply with the latest regulatory requirements.
• Document expiration risk: UN38.3 test reports, dangerous goods packaging certificates and other documents have a certain validity period. Enterprises need to update these documents in a timely manner to avoid customs clearance delays due to document expiration.
• Customs inspection risk: Customs may spot-check the declared lithium batteries. If problems such as inconsistent cargo with declaration or other issues are found, enterprises need to rectify or supplement materials, which may lead to customs clearance delays.
• Transportation safety risk: Lithium batteries still have safety risks such as short circuits and fires during transportation. Enterprises need to choose transportation companies with dangerous goods transportation qualifications and take effective safety measures to ensure the safe transportation of goods.

(B) Main Risks of Gray Customs Clearance

The risks of gray customs clearance are far greater than those of DG formal declaration and clearance. It not only violates customs regulations, but also brings huge economic losses and legal risks to enterprises.

• Legal risk: Gray customs clearance is an illegal act, and enterprises may face criminal penalties such as fines, detention or even fixed-term imprisonment.
• Economic risk: Goods may be detained or confiscated by customs, and enterprises will face huge economic losses. In addition, enterprises may also need to pay high fines and late fees.
• Commercial risk: Gray customs clearance will affect the reputation and image of enterprises, leading to customer loss and affecting the long-term development of enterprises.
• Supply chain disruption risk: Customs clearance delays may lead to delivery delays, affecting the cooperative relationship between enterprises and customers, and even leading to supply chain disruption.

VI. Best Practices and Recommendations for Compliance Exports

(A) Internal Management Recommendations for Enterprises

In order to ensure the compliance of lithium battery exports, enterprises need to establish a sound internal management system.

• Establish a compliance system: Formulate a compliance management system for lithium battery exports, clarify the responsibilities and authorities of each department, and ensure that the export behaviors of enterprises comply with regulatory requirements.
• Strengthen employee training: Improve employees’ awareness of export control policies and enhance their compliance awareness. Regularly organize employees to participate in relevant training to learn the latest regulatory policies and customs clearance processes.
• Choose compliant partners: Cooperate with freight forwarders and customs brokers with DG operation experience to ensure that the transportation and customs clearance processes of goods comply with regulatory requirements. When choosing partners, enterprises should strictly inspect their qualifications and reputation.
• Regularly review compliance: Regularly review and optimize the lithium battery export process, timely discover and solve existing problems, and ensure that the export behaviors of enterprises always comply with regulatory requirements.

(B) Strategies for Responding to Policy Changes

Export control policies may be adjusted at any time, and enterprises need to take effective strategies to respond to policy changes.

• Pay attention to policy dynamics: Timely understand the changes in export control policies, and obtain the latest policy information through government department websites, industry associations and other channels.
• Plan exports in advance: Arrange cargo exports before policy adjustments to avoid export delays due to policy changes. If enterprises have long-term export plans, they should communicate with customers in advance and negotiate to adjust the order time.
• Apply for export licenses: If goods are within the scope of control, enterprises need to apply for export licenses in advance. When applying for export licenses, enterprises should provide true and accurate materials to ensure that the application can be approved smoothly.
• Explore alternative solutions: Such as avoiding control through overseas factory construction, technology authorization and other methods. Enterprises can consider establishing production bases overseas and transferring lithium battery production to overseas, so as to avoid the impact of export control policies.

(C) Supply Chain Optimization Recommendations

Optimizing the supply chain is an important way to reduce the cost of lithium battery exports and improve export efficiency.

• Optimize packaging design: Use packaging materials and methods that meet international standards to improve the safety and reliability of packaging. At the same time, enterprises can also choose appropriate packaging schemes according to different transportation methods and destinations to reduce packaging costs.
• Reasonably choose transportation methods: Choose appropriate transportation methods according to the characteristics and time requirements of goods. For high-value goods and urgent orders, air transportation can be chosen; for large-batch goods, sea transportation can be chosen to reduce transportation costs.
• Purchase transportation insurance: Purchase dangerous goods transportation insurance to reduce risks during transportation. When choosing insurance products, enterprises should choose appropriate insurance schemes according to the value and risk level of goods.
• Establish an emergency mechanism: Formulate emergency plans for handling customs clearance delays, cargo detention and other emergencies to ensure that effective measures can be taken in a timely manner when problems occur to reduce losses.

Conclusion: Compliance Exports Are the Only Way for the Sustainable Development of the Lithium Battery Industry

Against the background of the rapid development of the global new energy industry, the lithium battery export market has broad prospects. However, with the continuous strengthening of export control policies, lithium battery exports are also facing increasingly stringent regulatory challenges. For lithium battery export enterprises, choosing compliant customs clearance methods is the only way to ensure the sustainable development of enterprises.

Although DG formal declaration and clearance may increase the cost and time investment of enterprises in the short term, it can ensure that the export behaviors of enterprises comply with regulatory requirements, reduce the risks of enterprises, and improve the reputation and image of enterprises. Although gray customs clearance may bring certain conveniences to enterprises in the short term, it violates customs regulations and will bring huge economic losses and legal risks to enterprises.

In the future, with the continuous improvement of global requirements for lithium battery safety and environmental protection, compliance exports will become the mainstream trend of the lithium battery industry. Enterprises should strengthen their compliance awareness, establish a sound compliance management system, choose compliant customs clearance methods, ensure that their export behaviors comply with regulatory requirements, and achieve sustainable development. At the same time, the government should also strengthen supervision, crack down on gray customs clearance behaviors, maintain a fair trade environment, and promote the healthy development of the lithium battery industry.