Effective September 1, 2026, the new battery consumption tax policy officially comes into force. Under this policy, phased taxation is reinstated for mature batteries with large‑scale industrial application, such as lithium‑ion accumulators and all‑vanadium redox flow batteries. Cutting‑edge technical routes including sodium‑ion batteries, solid‑state batteries, fuel cells, as well as perovskite and tandem photovoltaic batteries are eligible for phased consumption tax exemption valid from September 1, 2026 to December 31, 2028.
Key takeaway: Tax‑exempt status is not automatically granted merely by a product’s marketing name. Tax administration rules explicitly state that products applying for tax reduction or exemption must comply with relevant national standards. Before submitting the first tax reduction/exemption declaration, enterprises must obtain a qualified test report issued by a third‑party institution with CMA qualification.
1. Four Official Mandatory Requirements for Tax‑Exemption Test Reports
These requirements apply only to cutting‑edge battery products applying for tax exemption. Tax‑liable products such as lithium‑ion batteries and nickel‑metal hydride batteries do not require this tax‑exemption test report.
1、Product performance indicators must meet corresponding national standards.
2、The laboratory issuing the report must hold CMA metrology accreditation, and the relevant battery test items shall be covered in its qualification appendix.
3、The report shall include a detailed product list; product names and specifications / model numbers must match exactly with those shown on invoices and financial ledgers.
4、Enterprises shall keep the report for inspection. Enterprises bear legal responsibility for the authenticity of documentation, and tax authorities may access the report at any time during tax audits.
Supplementary note: The consumption tax scope covers battery cells, modules and PACK assemblies, not limited to battery cells alone. Customs HS codes cannot be directly used to judge a product’s tax‑exemption eligibility.
2. Four Common Misunderstandings That Enterprises Frequently Encounter
Misunderstanding 1: Products marketed as sodium‑ion / solid‑state batteries are automatically eligible for tax exemption
Marketing names have no legal validity. Tax authorities adopt measured data from CMA test reports. Even if the product name matches policy descriptions, tax exemption cannot be enjoyed if product indicators fail to satisfy national standard definitions.
Misunderstanding 2: A CNAS‑accredited report is sufficient
CNAS is a voluntary laboratory accreditation scheme. This policy accepts only CMA metrology‑accredited reports. Reports bearing only the CNAS mark without corresponding CMA qualifications, even from well‑known laboratories, cannot be used as supporting documents for tax‑exemption filing. Always review the laboratory’s CMA capability appendix before sample submission.
Misunderstanding 3: One report can cover an entire product series
A CMA report is bound to fixed specifications and model numbers and is valid only for products listed within it. Retesting is required for new models after product iteration or modification; one report cannot be reused long‑term. Consistency must be maintained across three sources: model numbers on test reports, on invoices, and in inventory ledgers.
Misunderstanding 4: Arrange testing only at the end of August
A sharp rise in sample submissions will occur before the new policy goes live, resulting in heavy laboratory scheduling backlogs. Sample preparation, testing and report review all require lead time. Submitting samples close to the declaration deadline may prevent you from receiving the report in time, and you will miss the tax‑exemption window directly.
3. Enterprise Compliance Practices: Three Critical Tasks
This is not solely the finance department’s work. Collaboration among R&D, quality, finance and sales teams is required.
1、Sort out product lists
Classify all products to separate tax‑liable mature batteries and cutting‑edge batteries intended for tax‑exemption application. Compile the full list of models requiring CMA testing. For products with ambiguous classification boundaries, conduct advance technical assessment and categorisation.
2、Select qualified institutions and submit samples off‑peak
Prioritise checking the laboratory’s CMA qualification appendix to confirm it possesses relevant battery testing capabilities; do not rely merely on institutional brand reputation. Start sample submission early to avoid pre‑policy submission peaks. Clearly inform the institution that the report will be used for consumption tax reduction / exemption filing.
3、Report archiving and internal alignment
Properly archive the official CMA report upon receipt. R&D confirms product technical attributes; quality teams preserve test documents; finance completes tax reduction/exemption declarations based on the report; sales fully incorporate tax‑burden fluctuation risks into contracts. When new products are revised or iterated, promptly evaluate whether supplementary testing is necessary.
This policy sends a clear signal: industry preferential policies will no longer depend simply on enterprise self‑declarations or concept‑driven marketing. Third‑party test data becomes the objective technical basis for policy implementation.
The tax exemption for sodium‑ion and solid‑state batteries is a phased policy, expiring on December 31, 2028. Enterprises should factor this deadline into product R&D and testing planning.
