India's Ban on Lithium-Ion Battery Black Mass Exports, Explained

On 10 November 2026, India's Directorate General of Foreign Trade stopped the export of a powder most readers have never had to name. Notification No. 49/2026-27 amended the export policy for lithium-ion battery black mass, under ITC(HS) code 85491400, from Free to Prohibited, with immediate effect and until further orders. The Press Information Bureau put the decision out at 4:07 pm IST on 11 November.

The order is narrower than "India banned battery exports", and wider than a press-release slogan about electric vehicles. It hits one customs line: unsorted waste and scrap that the notification calls black mass. It leaves a door, paragraph 1.05 of the Foreign Trade Policy, for commitments already locked in a letter of credit.

The 60-second version

• The order: DGFT Notification 49/2026-27, dated 10 November 2026. Export policy for ITC(HS) 85491400 moves from Free to Prohibited, immediately, until further orders. PIB Delhi, 11 November, 4:07 pm.
• What the code is: Unsorted waste and scrap of primary cells, primary batteries and electric accumulators, and spent cells, batteries and accumulators, not containing lead, cadmium or mercury. The notification names that item lithium-ion battery black mass.
• What the powder is: PIB: material from shredding end-of-life lithium-ion batteries and battery manufacturing waste, with recoverable lithium, cobalt, nickel and manganese.
• Why the government says it did this: Feedstock. PIB says Indian recycling capacity is underused because black mass is exported, and some domestic recyclers have had to import it. The ban is meant to keep the powder in the country.
• The two schemes people will mix up: A Rs 1,500 crore recycling incentive from September 2025, which is the scheme the PIB cites, and a Rs 2,814 crore processing scheme the Cabinet approved on 4 November 2026, which is the scheme The Indian Express cites for the timing. Different pots of money.
• What can still ship: Paragraph 1.05 of the Foreign Trade Policy, 2023. Exports already made are untouched. Later exports need an irrevocable commercial letter of credit from before the restriction, registered with the regional authority within 15 days.

What the customs line actually covers

The PIB's description of code 85491400 is specific. It covers waste and scrap of primary cells, primary batteries and electric accumulators, and spent cells, batteries and accumulators, which are unsorted and do not contain lead, cadmium or mercury. The notification then pins a name on that line: lithium-ion battery black mass.

ANI, in the copy carried by ThePrint on 11 November, quoted the notification's own sentence: the export policy of that described item "is amended from 'Free' to 'Prohibited' with immediate effect, until further orders." ThePrint's ANI copy adds the point that gets lost in headlines. The revised policy applies to the category the notification describes. It does not state a blanket prohibition on every battery or every battery-related material.

That distinction matters for anyone holding a different product. A finished cell, a cathode powder a refiner has already produced, or a sorted scrap stream that is not this code, is not what this notification amends. ANI also noted the legal hook: the Centre used Section 3 read with Section 5 of the Foreign Trade (Development and Regulation) Act, 1992, with the Foreign Trade Policy, 2023. The PIB says the notification is on the DGFT website.

The Indian Express, by Pratyush Deep, updated at 3:02 am IST on 12 November, quotes the notification's effect line almost as the PIB does: immediate effect, and paragraph 1.05 of the Foreign Trade Policy, 2023, on transitional arrangement. The Express description of the item matches the long customs name, including the bracketed words "Lithium-Ion Battery Black Mass". The paper's rendering has a hyphen slip ("Lithium-lon") in one place. The PIB spelling is lithium-ion.

What black mass is, in the government's words and in the paper's

The PIB definition is the one to use when the argument is about the notification. Black mass is "the powdery material obtained from shredding end-of-life lithium-ion batteries and battery manufacturing waste." It "contains recoverable quantities of critical minerals, including lithium, cobalt, nickel and manganese."

The Indian Express writes a wider ingredient list for the same powder: after waste lithium-ion batteries and consumer electronics are broken down, the powder contains lithium and also cobalt, manganese, silicon, tin, nickel, rhenium and graphite, among others. That list is the paper's. Silicon, tin, rhenium and graphite are not in the PIB sentence. Both descriptions can sit together. The PIB names the minerals it is making the policy about. The Express is describing what recyclers say is in the powder.

ANI, via ThePrint, adds the next industrial step without putting a recovery percentage on it. Through further chemical processing, particularly hydrometallurgy, recyclers can recover these materials and convert them into compounds used in battery manufacturing. No recovery rate is in the PIB note or in that ANI copy. A percentage floating on social media is not from these documents.

Why keep a powder the country also struggles to refine

The PIB's case is about feedstock, not about a sudden surplus of refining skill. India "depends substantially on imports" for several of these minerals. Recycling is described as among the quickest ways to build a domestic supply. Capacity to recycle battery waste and refine minerals from it "has grown considerably" and "is not being fully utilised" because feedstock is inadequate. Exports "divert this valuable secondary resource abroad, while domestic recyclers have, in some cases, had to import material."

The Indian Express puts numbers on that capacity claim and attributes them to government data. It said 57 lithium-ion battery recyclers are registered on the Central Pollution Control Board's battery-waste extended-producer-responsibility portal, with combined annual processing capacity of 5.17 lakh metric tonnes. Input capacity specifically for processing lithium-ion battery black mass is estimated at about 75,500 metric tonnes a year. Those figures are in the Express story. They are not in the PIB release. The gap between 5.17 lakh tonnes of battery-waste processing and 75,500 tonnes of black-mass input is the paper's picture of how much of the industry can actually take this powder apart, as against how much can take batteries in.

Shyamasis Das, a fellow at the Centre for Social and Economic Progress, told the Express that stopping the export is in India's interest because of the minerals in the powder, and that getting those minerals out at the required grade takes technical know-how. "Some industry players take the easier route which is selling black mass in the international market instead of recovering the minerals," he said. He said the powder largely ends up with recyclers in China, which has the largest recycling capacity and a large cell-manufacturing industry that wants recycled minerals. His closing point is the loop: "India has to develop domestic cell manufacturing capacity to close the loop of the battery circular economy." That is Das's view, reported by the Express. It is the clearest public argument for why a ban on exporting powder does not, by itself, produce cathode material.

The Express also records the other explanation officials have used for why the powder was leaving: limited domestic recycling and refining capability. The PIB does not deny that limit. It says capacity has grown and is underfed. Both sentences are in the public record. A ban addresses the export. It does not install a refinery.

Two schemes, two crore figures

The PIB release ties the ban to the National Critical Mineral Mission, and specifically to a Rs 1,500 crore incentive scheme the Union Cabinet approved in September 2025 for recycling capacity that separates and produces critical minerals from secondary sources such as battery waste and e-waste. Retaining black mass, the PIB says, is how that capacity gets domestic feedstock. The same release says the step matches what several major economies have done to keep critical-mineral-bearing battery waste at home. It does not name those economies.

The Indian Express places the ban "days after" a different Cabinet decision: a scheme for capital-expenditure support for critical-mineral processing, outlay Rs 2,814 crore, focused on lithium and nickel processing, for electric mobility, battery storage, electronics, defence and specialty steel. That approval, on 4 November, is the subject of our lithium and nickel processing explainer. The Express is right about the calendar. The PIB release on the ban does not cite the Rs 2,814 crore scheme. It cites the Rs 1,500 crore recycling scheme. Readers who collapse them into one "critical minerals package" are mixing a trade ban, a recycling incentive and a processing subsidy.

There is a third official line, older, in the Express story. In March, the Ministry of Heavy Industries, citing the Society of Indian Automobile Manufacturers, told Parliament that India's entire current demand for lithium is met through imports, so the electric-vehicle supply chain is sensitive to external shocks. The ministry also told Parliament, as the Express reported it, that China's export controls and licensing on high-performance lithium-ion batteries, cathode materials, artificial-graphite anodes and associated manufacturing technology could tighten near-term supply, and that Indian EV makers who rely on Chinese midstream processing face that vulnerability. That is a March statement to Parliament, relayed by the Express in November. It is context for why a secondary source of lithium matters. It is not a sentence in the 10 November notification.

What paragraph 1.05 actually lets through

The notification does not spell the transitional rule out. It points at paragraph 1.05 of the Foreign Trade Policy, 2023. The policy text, in the Foreign Trade Policy document published by Invest India, splits that paragraph. Sub-paragraph (a) is about licences and scripts issued before the 2023 policy. Sub-paragraph (b) is the one that matters here.

Under 1.05(b), whether an item can be imported or exported is governed by the policy on the date of import or export. The date of export is defined in paragraph 2.17 of the Handbook of Procedures, 2023, and the policy says the shipping bill is a key document for that date. If policy changes from free to restricted, prohibited, state trading, or otherwise regulated, import or export already made before the change is not affected. Import or export on or after the change is allowed for an importer or exporter who has a commitment through an irrevocable commercial letter of credit from before the restriction, and only up to the balance quantity, value and period in that letter of credit. The applicant has to register the letter of credit with the jurisdictional regional authority, against a computerised receipt, within 15 days of the restriction. The same paragraph says a policy change applies prospectively from the date of the notification unless the notification provides otherwise. This notification says it is immediate, and that 1.05 applies. It does not add a special window of its own.

A plain purchase order, or a contract that is not an irrevocable commercial letter of credit, is not what 1.05(b) names. Exporters who think "we had a deal" is enough are ahead of the paragraph. The policy text also says high-sea sales are not covered by the facility that protects imports already in train. That sentence is about imports. It is not a second export loophole.

What to watch next

1. The gazette copy and any customs circular. ANI said the decision was taken under the foreign-trade law and the 2023 policy. A customs instruction would be how the line is enforced at the port, including how officers treat a letter of credit registered inside the 15 days.
2. Whether the 75,500-tonne black-mass capacity actually fills. The Express figure, from government data, is an estimate of input capacity, not a statement that those tonnes of powder are sitting in India waiting for a buyer. The PIB's claim is that exports were starving domestic units. The test is utilisation, which neither document prints as a percentage.
3. The China outlet Das described. If Chinese recyclers were the main buyers, the ban changes their feedstock and Indian recyclers' selling option at the same time. Das's point stands next to that: without cell manufacturing at home, recovered minerals can still leave as a later product, which this notification does not ban.
4. The Rs 2,814 crore plants and the Rs 1,500 crore recycling incentive. One builds processing. One was supposed to build recycling. The ban is the government's attempt to feed both. It does not, in the PIB note, set a price for black mass or a purchase obligation on the new plants.
5. Parliament's March line on import dependence. The ministry told the House, via SIAM, that current lithium demand is fully imported. A ban on exporting powder does not change that sentence until someone in India is producing lithium compounds from the powder at a scale the import bill can feel.

The 10 November notification closes one customs line, 85491400, that had been Free. It keeps the powder, as the PIB defines it, inside India unless an older irrevocable letter of credit still has room. It does not ban batteries, and it does not refine the powder. That work is the point of two different crore schemes, and of a capacity figure, 75,500 tonnes for this specific input, that is far smaller than the headline recycling number.

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This explainer uses the Press Information Bureau release "DGFT prohibits export of Lithium-Ion Battery Black Mass to strengthen domestic recycling and critical mineral recovery" (PIB Delhi, 11 November 2026, 4:07 pm, Abhishek Dayal, Abhijith Narayanan and Ishita Biswas, Ministry of Commerce and Industry) for Notification No. 49/2026-27, the 10 November date, the Free-to-Prohibited change, code 85491400, the definition of that code, the definition of black mass, the minerals lithium, cobalt, nickel and manganese, the feedstock rationale, the Rs 1,500 crore incentive scheme of September 2025, the National Critical Mineral Mission reference, and the statement that the notification is on www.dgft.gov.in. The Indian Express (Pratyush Deep, New Delhi, updated 12 November 2026, 3:02 am IST) is the source for the notification's quoted effect line, the wider mineral list, the "days after" link to the Rs 2,814 crore processing scheme, the government-data figures of 57 recyclers, 5.17 lakh metric tonnes and about 75,500 metric tonnes, the quotes from Shyamasis Das of the Centre for Social and Economic Progress, and the March parliamentary reply by the Ministry of Heavy Industries citing SIAM, including the China export-control passage. ANI, as carried by ThePrint on 11 November 2026, is the source for the notification's quoted policy sentence, the statement that the order is not a blanket ban on every battery or battery-related material, the hydrometallurgy description, and the reliance on Section 3 read with Section 5 of the Foreign Trade (Development and Regulation) Act, 1992. Paragraph 1.05 is quoted from the Foreign Trade Policy 2023 text as published by Invest India. The Rs 2,814 crore scheme's own terms are in our 4 November explainer, drawn from that day's PIB note. This is not legal, customs or investment advice. Exporters should read the notification and paragraph 1.05 against their own documents.