Import Surveillance Requirements for Lithium-Ion Batteries Communiqué No: 2026/19

Executive Summary

Import Surveillance Communiqué (No: 2026/19) introduces a value-based import surveillance regime for lithium-ion batteries, classified under HS heading 8507.60. The regulation establishes minimum unit customs value thresholds calculated on a gross weight basis (USD per kilogram), differentiated by voltage level. Imports declared below these thresholds are subject to a mandatory Surveillance Certificate requirement. The Communiqué enters into force 30 days after its publication on 31 December 2025.

Scope of the Regulation

The surveillance measure applies to lithium-ion batteries under HS 8507.60, segmented by operating voltage:

• Batteries with a voltage of 4.9 volts or more but not exceeding 400 volts fall under surveillance when declared below USD 12 per kilogram (gross weight).
• Batteries with a voltage exceeding 400 volts are subject to surveillance when declared below USD 15 per kilogram (gross weight).

Only imports declared at or above the applicable reference values may be released without surveillance certification.

Mandatory Surveillance Certificate

Where the declared unit value falls below the relevant reference threshold, importation is permitted only upon presentation of a valid Surveillance Certificate issued by the Ministry of Trade. The certificate must be obtained prior to registration of the customs declaration and must be correctly referenced in the declaration using the assigned document number and issue date.

Failure to present a valid certificate will result in customs clearance being blocked, regardless of battery capacity, end-use application (e.g., consumer electronics, energy storage, or electric vehicles), or contractual pricing.

Application and Review Process

Applications for Surveillance Certificates are submitted electronically through the national Single Window system using the designated industrial surveillance document type and selecting Communiqué No: 2026/19 as the legal basis. A qualified electronic signature is required, with an alternative submission channel available via the national e-government portal.

Where electronic submission is not technically feasible, physical applications may be accepted using the prescribed application form together with corporate registration documentation.

During the review stage, the authority may request original documents, technical specifications (including voltage characteristics), or supplementary explanations. Any inconsistency, deficiency, or contradiction identified will suspend issuance until fully remedied.

Customs Value Clarification and Practical Application

The Communiqué explicitly states, in a separate provision, that the reference values introduced for surveillance purposes do not replace and do not constitute customs value. General customs valuation rules remain fully applicable.

In practice—and specifically for value-based surveillance regimes—it is possible to structure the declared customs value by including legitimate foreign cost elements, such as international freight, insurance, royalties, or other overseas charges. By lawfully declaring these elements, the final customs value may be increased above the surveillance reference threshold, allowing the import to proceed without a Surveillance Certificate. This practice is accepted by customs authorities, provided that all cost components are genuine, properly documented, and declared in full compliance with valuation rules.

This approach applies only to value-based surveillance measures and does not extend to quantity-based or non-value surveillance regimes.

Validity and Legal Effect

Surveillance Certificates issued under this Communiqué are valid for six months from the date of issuance. The existence of a certificate does not prevent customs authorities from examining or reassessing the declared value under general valuation principles. Conversely, accurate and well-documented valuation may allow clearance without surveillance certification where thresholds are legitimately exceeded.

Enforcement and Compliance Risk

If inaccurate, misleading, or incomplete information is identified during the application or review stages, issuance of the Surveillance Certificate will be withheld until corrective action is taken. Non-compliance may lead to customs delays, additional storage costs, and increased scrutiny during post-clearance audits.

Entry into Force

The Communiqué enters into force on the 30th day following its publication date. Importers should review contracts, pricing structures, and logistics cost allocation for shipments scheduled around the effective date to ensure uninterrupted customs clearance.

Compliance Assessment

From a customs compliance and trade risk management perspective, this regulation directly affects a strategic, high-growth product group with significant price variation depending on technology, energy density, and end use. Importers of lithium-ion batteries should reassess product classification, voltage specifications, supplier pricing, and cost allocation well in advance of shipment.

For value-based surveillance, lawful inclusion of overseas cost components can provide operational flexibility, provided documentation is robust and internally consistent. A shipment-by-shipment assessment is strongly recommended to determine whether surveillance can be avoided through correct valuation or whether proactive application for a Surveillance Certificate offers greater predictability and risk control.

See relevant legislative document.