(1) Core enforcement logic

Using integrated vehicle-battery scrappage + unique digital traceability + full-process control of hazardous waste as the key measures, the goal is to cut off the gray chain, leaving small workshops unable to collect, unable to transport, unable to dismantle, and unable to sell, while creating strong deterrence through heavy fines + removal from the white list + revocation of fiscal and tax qualifications + criminal liability.

(2) Key enforcement points by link (targeted crackdown on small workshops)

Source blocking: scrappage stage (Ministry of Commerce)

Strictly investigate vehicle-battery separation, scrappage enterprises illegally issuing recycling certificates, and privately selling batteries to small workshops.

If the battery is missing, no scrappage certificate will be issued, blocking private transactions at the source; illegal sales are subject to fines of up to 30 万元.

Track locking: traceability stage (Ministry of Industry and Information Technology)

Each battery has a unique digital ID, traceable throughout its entire life cycle, with strict investigation into unreported or falsely reported traceability information.

Missing data directly affects white list evaluation, and false information is subject to fines of up to 50 万元, closing the loophole of "unclear source" for small workshops.

Road inspection and interception: transportation stage (Ministry of Transport)

Retired power batteries are classified as Class 9 hazardous waste, and transportation without hazardous cargo qualifications and mixed transport with ordinary trucks will be strictly investigated.

Vehicle impoundment + administrative penalties, and criminal liability will be pursued in cases involving leakage or fire, cutting off logistics channels for small workshops.

Eliminating dens and making arrests: dismantling stage (Ministry of Ecology and Environment)

Strictly investigate construction before approval, no environmental impact assessment, no pollutant discharge permit, and direct discharge of wastewater and exhaust gas, which is the core link in cracking down on small workshops.

Penalties may be imposed continuously on a daily basis with no upper limit, and environmental pollution crimes may carry sentences of up to 15 years, directly shutting down and eradicating illegal dens.

End-market clearance: circulation stage (State Administration for Market Regulation)

It is strictly prohibited to refurbish retired power batteries for use in electric bicycles / balance scooters, and unlicensed operations and unqualified products will be strictly investigated.

Confiscation + penalties + full-chain traceability. Once a fire or explosion occurs, accountability will be pursued across every link, completely cutting off the profiteering outlet for small workshops.

(3) The power of the enforcement "combination punch" (far beyond a one-time fine)

One violation → removal from the white list → loss of VAT refund upon collection→ annual loss of 500-700 万元,exceeding 3000 万元 over three years.

At the same time, access to SOE supply chains, green credit, and environmental tax reduction qualifications will also be lost, and the compliance cost advantage will disappear completely.

Photovoltaic modules are about to enter a peak retirement period, and currently face the same pain points such as the proliferation of small workshops, insufficient feedstock for正规 enterprises, high environmental risks, and lack of traceability.

Photovoltaic recycling is now in a policy window period. If this model is directly adopted, it can help avoid in advance the detours experienced by the power battery sector and achieve orderly retirement, standardized recycling, and green utilization.

Establish a white list for photovoltaic recycling and implement a dynamic assessment + exit mechanism to prevent a rush of entrants and excess capacity.

Drawing on the unique battery traceability code, establish a full-life-cycle traceability platform for photovoltaic modules to record information covering the entire process of production, installation, O&M, retirement, recycling, and dismantling.

Establish a joint law enforcement mechanism among the Ministry of Industry and Information Technology + the Ministry of Ecology and Environment + the National Energy Administration + the State Administration for Market Regulation, covering the entire chain of dismantling — transportation — storage — disassembly — resource recovery.

Clearly define penalties for unqualified dismantling and illegal pollutant discharge by small workshops.