Core Viewpoint - The China Securities Regulatory Commission (CSRC) has announced additional requirements for overseas listing applications, specifically targeting Flashback Technology and its shareholder structure [1][2]. Group 1: Company Overview - Flashback Technology is a Chinese company focused on providing recycling services for consumer electronics, particularly second-hand mobile phones [2]. - According to Frost & Sullivan, Flashback Technology ranks as the third-largest mobile phone recycling service provider in China, with a market share of approximately 1.3% for both the total transaction value of recycled second-hand phones and sold second-hand phones in 2024 [2]. Group 2: Regulatory Requirements - The CSRC requires Flashback Technology to clarify its equity structure and shareholder transparency, including any historical equity holding arrangements [1]. - The company must conduct a thorough investigation into the overseas investors of Shanghai Xiuhui and explain the reasons for the cessation of transparency regarding Tianjin Jinmi Investment Partnership [1]. - Additional information is required regarding the compliance of the company's major domestic operating entities with foreign investment reporting obligations and foreign exchange registration procedures [2].

Group 1 - ShanH Technology Limited, based in Anji County, Huzhou, Zhejiang, has submitted its IPO application to the Hong Kong Stock Exchange after two previous failed attempts in February and September 2024 [3] - The company specializes in providing recycling services for consumer electronics, focusing on trade-in programs for used mobile phones and other electronic products [5][6] - According to Frost & Sullivan, ShanH Technology is the third-largest mobile phone recycling service provider in China, with a market share of approximately 1.3% in both the total transaction value of recycled and sold used mobile phones [5] Group 2 - The company has developed two core brands: "ShanH Recycling" and "ShanH Quality Products," primarily sourcing used electronics through trade-in transactions at online and offline stores [6] - Revenue is mainly generated from sales of second-hand electronic products through the "ShanH Quality Products" online platform and third-party e-commerce platforms [6] - Financial performance shows revenues of RMB 750 million, RMB 919 million, RMB 1.16 billion, RMB 1.30 billion, and RMB 809 million for the years 2021 to 2025 (first half) respectively, with corresponding net losses [12][13] Group 3 - The shareholder structure prior to the IPO indicates that Liu Jianyi holds 31.71% through ShanHuiShou BVI, with other significant shareholders including MGY Wisdom BVI and Xiaomi [8][9] - The board of directors consists of eight members, including four executive directors and three independent non-executive directors, with Liu Jianyi serving as the chairman and CEO [11] - The IPO's intermediary team includes QianKe Capital as the sole sponsor and KPMG as the auditor [13]