【编者按】动力电池退役正在加速到来。退役电池既是富含镍、钴、锂等战略性金属资源的重要"城市矿山"，也是必须被严格纳入合规体系的安全与环境风 险源。2026年1月，工信部等六部门印发《新能源汽车废旧动力电池回收和综合利用管理暂行办法》，推动动力电池回收行业进入强约束阶段。强监管落地 后，更现实的问题随之浮现。 企业需要补齐哪些关键动作？"电池身份证"等溯源机制将如何真正管住电池流向、压实主体责任，并在此基础上与国际规则逐步接轨？合规成本谁来承担、 怎么分摊，才能支撑行业跑出可持续的商业闭环？围绕这些关键议题，绿色和平联合中汽数据有限公司与中国矿业大学化工学院推出系列专家文章，聚焦政 策升级、数字化溯源与合规成本等主题，系统解析强监管时代下动力电池回收体系中企业的应对路径。 文 | 中汽数据、绿色和平、中国矿业大学化工学院研究团队 2026年1月，工信部印发《新能源汽车废旧动力电池回收和综合利用管理暂行办法》（下称《管理暂行办法》），标志着动力电池回收与综合利用行业进入 强约束阶段。 新规从多个维度对废旧电池回收管理体系进行了系统优化，包括细化各环节主体责任、强化全生命周期电池溯源体系、完善多部门协同监管机制等。 ...

Core Viewpoint - The Ministry of Industry and Information Technology and five other departments have jointly issued the "Interim Measures for the Recycling and Comprehensive Utilization of Waste Power Batteries from New Energy Vehicles," emphasizing a management approach that covers the entire lifecycle of batteries, requiring that scrapped vehicles must include their power batteries, which will have a digital identity [1] Group 1: Regulatory Framework - The new regulations aim to prevent the illegal recycling of waste power batteries by ensuring that scrapped vehicles are accompanied by their batteries, with specific provisions for non-replaceable battery models being developed separately [2] - The measures introduce new requirements for the comprehensive utilization of waste batteries, eliminating the concept of "second-use" batteries to ensure safety and compliance with quality standards [3] Group 2: Recycling and Utilization - The recycling of waste power batteries is crucial as they contain valuable metals like nickel, cobalt, manganese, and lithium, as well as hazardous substances that can harm the environment if not properly managed [1][3] - The recycling rates achieved by some companies have reached 99.6% for nickel, cobalt, and 96.5% for lithium, demonstrating significant economic, social, and ecological benefits [4] Group 3: Management Approach - The measures follow a "full-channel, full-chain, full-lifecycle" management strategy, which includes standardized management of battery production, vehicle scrapping, battery swapping operations, and maintenance [5][6] - A nationwide information platform will be established to track the lifecycle of power batteries, with each battery receiving a unique digital identity to facilitate monitoring and compliance [7]

Core Viewpoint - The introduction of the "Interim Measures for the Recycling and Comprehensive Utilization of Waste Power Batteries for New Energy Vehicles" marks a significant regulatory shift aimed at establishing a comprehensive management framework for battery recycling, emphasizing lifecycle management and digital solutions to enhance the sustainability of the new energy vehicle industry [1][2]. Group 1: Regulatory Innovations - The "Vehicle-Battery Integrated Scrapping" system addresses industry pain points by mandating that scrapped vehicles must include their power batteries, preventing the illegal sale of batteries in black markets [1][2]. - The digital identity management system for power batteries introduces unique dynamic codes for each battery, enabling full-chain traceability and proactive regulatory measures, which can enhance consumer confidence and optimize resource allocation for companies [1][2]. - A comprehensive responsibility system and strict penalty mechanisms are established, holding all stakeholders accountable and imposing administrative penalties for non-compliance, with severe cases potentially leading to criminal liability [2][3]. Group 2: Challenges in Implementation - Market-level challenges include the need to address the knowledge gap and financial concerns of vehicle owners, particularly those in the ride-hailing and freight sectors, who may resist the new regulations due to perceived short-term financial losses [2][3]. - Small and medium-sized enterprises face significant compliance costs and technical adaptation challenges, which may lead to the elimination of potentially viable companies during industry consolidation [3][4]. - Regulatory challenges include regional disparities in enforcement capabilities and the need for improved data-sharing mechanisms among departments to effectively identify and address violations [3][5]. Group 3: Recommendations for Successful Implementation - The establishment of a market-based recycling pricing mechanism and incentives for compliant battery disposal can help balance interests and reduce the appeal of black market sales [4][5]. - Government support for small enterprises through subsidies, low-interest loans, and tax reductions can facilitate compliance and encourage collaboration among industry leaders to support smaller firms [4][5]. - Strengthening grassroots enforcement capabilities and enhancing inter-departmental collaboration are crucial for effective regulation, alongside the development of detailed technical standards for battery recycling and utilization [5].

Group 1 - The core viewpoint of the articles highlights the continuous improvement of China's green manufacturing service system during the "14th Five-Year Plan" period, with the emergence of "waste-free parks," "waste-free enterprises," and green factories, accelerating the transformation and upgrading of production methods towards greenness [1][2] - By 2025, the comprehensive utilization of waste power batteries from new energy vehicles in China is expected to exceed 400,000 tons, with various sectors increasingly adopting "waste-to-resource" practices [1] - The latest data shows that during the "14th Five-Year Plan," the reuse rate of industrial water in large-scale industries in China exceeds 94%, and the comprehensive utilization rate of major industrial solid waste reaches 57% [1] Group 2 - The efficiency of resource utilization is continuously improving, with the energy structure of industrial use being optimized; by 2025, the use of renewable energy in green computing facilities in China is expected to exceed 70% [2] - As of now, China has cultivated over 8,000 national-level green factories and more than 600 green industrial parks [2] - During the "14th Five-Year Plan," the output value of green factories accounted for 22% of the total output value of the manufacturing industry, up from 9%, with a cumulative reduction of over 13.5% in energy consumption per unit of added value in large-scale industries [2]

Core Viewpoint - The introduction of a "digital identity" for every power battery in China's new energy vehicle industry marks a significant institutional reform, transitioning the industry from chaotic growth to regulated maturity, with a projected market scale exceeding 100 billion yuan by 2030 [1][3]. Group 1: Industry Transformation - The new regulation will enforce a "vehicle-battery integrated scrapping" policy, fundamentally altering the operational landscape and ensuring stable raw material supply for compliant enterprises [1][2]. - The current stock of new energy vehicles in China has surpassed 40 million, leading to an impending wave of battery retirements, with annual retirements expected to exceed 1 million tons by 2030 [1]. Group 2: Lifecycle Management - The establishment of a tracking system for batteries will create a dynamic "life file," enhancing regulatory oversight and curbing illegal circulation while enabling new business models based on accurate data [2][3]. - The system will drive optimization across the industry chain, necessitating design considerations for recyclability, production traceability, and battery health monitoring [2]. Group 3: Competitive Landscape - Future competition will hinge on digital capabilities, with companies that effectively utilize traceability data to optimize recycling networks and accurately assess battery residual value gaining a competitive edge [2][3]. - Leading companies are already achieving breakthroughs in recycling technologies, allowing for efficient extraction and recycling of key metals, which will translate into tangible competitive advantages in a regulated market [2]. Group 4: Implementation Challenges - Successful execution of the digital identity system relies on the integrity of data, supported by IoT technology and clear responsibility mechanisms, alongside a well-functioning recovery network [3][4]. - Long-term sustainability in the market will depend on ensuring that compliant businesses achieve real economic benefits and that the costs of recycling are lower than those of raw material extraction [3][4].

Core Viewpoint - The rapid growth of China's new energy vehicle industry has led to a surge in retired power batteries, prompting the need for standardized recycling and utilization practices, as highlighted by the recent issuance of the "Interim Measures for the Management of Recycling and Comprehensive Utilization of Waste Power Batteries for New Energy Vehicles" by six government departments, marking a new phase in regulatory management for battery recycling [1][2]. Group 1: Regulatory Framework - The new management measures significantly enhance legal constraints compared to previous frameworks, addressing the inadequacies of the 2018 traceability management regulations [2]. - A notable innovation is the establishment of a digital identity management system for power batteries, which will enable real-time monitoring and information tracing throughout the battery's lifecycle, from production to recycling [2][4]. - The measures impose clear responsibilities on all parties involved and outline administrative penalties for non-compliance with recycling obligations and improper handling of waste batteries [4]. Group 2: Industry Development - China has established a recycling network across 31 provinces, nurturing 148 key enterprises in comprehensive utilization, with recovery rates for lithium, cobalt, and nickel at internationally advanced levels [5]. - Nearly 30 national standards have been released, covering various aspects of recycling, and the market regulatory authority aims to accelerate the development and implementation of these standards to guide high-quality industry growth [5]. - The introduction of these measures is seen as a milestone in transitioning the battery recycling industry from chaotic growth to high-quality development, promoting collaboration across the supply chain and maximizing the residual value of retired batteries [5].

Core Viewpoint - The new regulations for the recycling and comprehensive utilization of used power batteries from new energy vehicles (NEVs) will take effect on April 1, 2026, addressing the urgent need for standardized recycling processes as the first batch of NEVs approaches retirement [1]. Group 1: Regulations on Non-Swap Battery Vehicles - For non-swap battery vehicles, the core requirement is that the power battery must be handed over together with the vehicle to a qualified recycling and dismantling organization upon retirement [2]. - By 2025, the total amount of retired power batteries in China is expected to reach 820,000 tons, and it is projected to exceed 1 million tons by 2030 [2]. - The new regulations include a "digital ID" for each battery, allowing for full lifecycle tracking from production to recycling, which aims to prevent illegal sales and ensure consumer protection [2]. Group 2: Clarifications for Battery Replacement and Recycling Channels - Vehicle owners are advised to keep records of battery replacements and recycling receipts to avoid complications during the vehicle retirement process [3]. - The regulations require battery manufacturers to establish recycling points in each province, while NEV manufacturers must cover recycling points down to the prefecture level, simplifying the recycling process for vehicle owners [3]. - Strict penalties are established for those who illegally repurpose used batteries for other applications, with fines ranging from 10,000 to 100,000 yuan for serious violations [3]. Group 3: Exemptions for Swap Battery Vehicles - Swap battery vehicles are exempt from the "vehicle-battery integration" requirement, recognizing the unique nature of the battery swap model [4]. - The decision to exempt swap vehicles is based on the growing prevalence of battery swap networks, such as those operated by NIO and CATL, which have established extensive infrastructure [4]. - The regulations will allow for different ownership models of batteries, whether purchased outright or rented, without requiring the battery to be returned with the vehicle upon retirement [4]. Group 4: Recycling Technology and Market Regulation - The recycling technology for used power batteries in China has matured, with some companies achieving recovery rates of 99.6% for nickel-cobalt-manganese and 96.5% for lithium [5]. - The implementation of the new regulations is expected to further reduce illegal recycling activities, leading to a more regulated and orderly recycling market [5]. - The overall lifecycle management system for NEVs will become more robust, enhancing environmental protection and public safety while improving the user experience for vehicle owners [6].

Core Viewpoint - The introduction of the "Interim Measures for the Recycling and Comprehensive Utilization of Used Power Batteries for New Energy Vehicles" marks a new phase in the standardized management of used power battery recycling in China, addressing the increasing volume of waste batteries due to the rapid development of the new energy vehicle industry [2][4]. Group 1: Regulatory Framework - The new management measures significantly enhance legal constraints and aim to resolve existing issues in the recycling process, such as unregulated sales and dismantling of used batteries [5][4]. - The previous regulations from 2018 will be abolished, and a digital identification system for power batteries will be established to monitor their lifecycle and ensure compliance [4][7]. Group 2: Industry Development - By 2025, the comprehensive utilization of used power batteries in China is expected to exceed 400,000 tons, reflecting a year-on-year growth of 32.9%, with leading companies achieving international standards in metal recovery rates [3]. - The management measures will require companies to adhere to new conditions for engaging in comprehensive utilization, focusing on compliance and environmental protection [7][8]. Group 3: Stakeholder Responsibilities - The recycling and utilization of used power batteries require collaboration among various stakeholders, including policy, market, technology, and standards [6]. - The government has established a recycling network across 31 provinces and has cultivated 148 leading enterprises in the comprehensive utilization sector [6]. Group 4: Public Participation - The measures emphasize the importance of public involvement in the recycling process, urging consumers to understand and comply with battery recycling guidelines when purchasing new energy vehicles [9]. - The call for collective responsibility highlights the need for consumers to ensure that used batteries are disposed of through regulated channels to prevent environmental hazards [9].

Core Viewpoint - The article discusses the rising demand for "disassembled batteries" sourced from retired electric vehicle batteries, highlighting the regulatory challenges and market dynamics surrounding their use in electric bicycles and other applications [1][4][5]. Group 1: Market Dynamics - The demand for disassembled batteries is driven by their lower cost and higher performance compared to original batteries, appealing particularly to delivery riders and couriers [1][2]. - A disassembled battery can provide a range of up to 80 kilometers, significantly more than the original battery's 40 kilometers [1]. - The price of a disassembled battery is approximately 3,000 yuan, which is about 500 yuan cheaper than a new battery of the same specifications [2]. Group 2: Regulatory Environment - The Ministry of Industry and Information Technology has issued new regulations prohibiting the use of retired batteries in electric bicycles, effective from April 1, 2026 [1][5]. - The concept of "cascade utilization" for retired batteries has been eliminated, which previously allowed for their use in various applications [5]. - The new regulations emphasize the "vehicle-battery integration" requirement for the scrapping of electric vehicles, mandating that batteries must be included during the scrapping process [5]. Group 3: Industry Challenges - A significant portion of retired batteries, estimated at 80%, is reportedly missing from vehicles before they reach authorized recycling facilities, indicating a leakage into unregulated markets [4]. - The recycling capacity of legitimate battery recycling companies is underutilized, with estimates suggesting that only 25% of their capacity is currently being used [4]. - The rapid growth of the electric vehicle market has led to an urgent need for a robust battery recycling infrastructure to manage the increasing volume of retired batteries [6][9]. Group 4: Future Projections - The domestic battery recycling volume is projected to exceed 300,000 tons by 2024, with the number of retired lithium batteries expected to reach 981,600 tons by 2026 [7][8]. - The market for recycled materials from lithium batteries is anticipated to grow significantly, with sales expected to reach 856,100 tons by 2025 and 1,204,500 tons by 2026 [10].

Core Viewpoint - The recycling and utilization of used power batteries from new energy vehicles is crucial for ecological safety and sustainable resource use, attracting significant investor attention while also facing various industry challenges [1] Group 1: Regulatory Framework - The Ministry of Industry and Information Technology, National Development and Reform Commission, and Ministry of Ecology and Environment, among others, have jointly issued the "Interim Measures for the Management of Recycling and Comprehensive Utilization of Used Power Batteries from New Energy Vehicles," emphasizing a "full-channel, full-chain, full-lifecycle" management approach to promote industry standardization [1] - The new regulations introduce a "vehicle-battery integrated scrapping" system, mandating that scrapped new energy vehicles must include their power batteries, or they will be deemed as lacking essential components [2] Group 2: Market Potential and Growth - The domestic power battery recycling market is projected to exceed 100 billion yuan by 2030, driven by the rapid development of the new energy vehicle industry [1] - As of October 31, 2025, nearly 180,000 battery recycling-related enterprises are expected to exist in China, with over 30,000 new registrations in the first ten months of 2025, marking a growth of over 15% compared to the same period in 2024 [1] Group 3: Industry Challenges - The emergence of unqualified small workshops and "black factories" operating at low environmental and safety costs poses significant risks, leading to a phenomenon where some scrapped vehicles have their batteries illegally removed before reaching authorized dismantling facilities [2] - The lack of standards and insufficient safety assessments in the secondary utilization of retired power batteries has allowed some enterprises to exploit loopholes, resulting in safety hazards [3] Group 4: Standardization and Compliance - The new regulations eliminate the concept of "secondary utilization" and prohibit any organization or individual from using used power batteries directly or after processing in electric bicycles or other fields banned by laws and regulations [4] - A three-year special action against illegal disposal of solid waste, focusing on the illegal dismantling of used power batteries, will be launched by the Ministry of Ecology and Environment and seven other departments in 2025 [4] Group 5: Future Directions - For the healthy development of the industry, there is a need for technological innovation and public participation, with companies encouraged to enhance the intelligence of recycling processes and consumers urged to responsibly dispose of used batteries through legitimate channels [4][5]