On October 31, the China Securities Regulatory Commission (CSRC) released its "Supplementary Material Requirements for Overseas Listing Filings (October 27-31, 2025)." The CSRC's international department issued supplementary material requests to nine companies, including Guangzhou Tinci Materials Technology Co.,Ltd. (002709.SZ), which was asked to clarify whether its completed, ongoing, and proposed fundraising projects qualify as "high-energy-consumption" or "high-emission" projects, along with details about the establishment and disclosures of its Hong Kong subsidiary.
Tinci Materials submitted its main board listing application to the Hong Kong Stock Exchange on September 22, 2025, with J.P. Morgan, CITIC Securities, and GF Securities serving as joint sponsors. The CSRC requested Tinci Materials to provide additional explanations on the following matters, requiring legal verification and clear opinions:
1. Clarify whether domestic subsidiaries fall under circumstances prohibiting overseas listings as stipulated in Article 8 of the "Trial Measures for the Administration of Overseas Securities Offering and Listing by Domestic Companies." 2. Specify if completed, ongoing, and proposed fundraising projects qualify as "high-energy-consumption" or "high-emission" projects, with supporting evidence. 3. Detail operational activities related to business scopes including "battery manufacturing," "lithium-ion battery manufacturing," "power battery manufacturing," and "other unspecified battery manufacturing." 4. Explain the establishment and disclosure status of Hong Kong Tinci, its actual business operations, and legal compliance evidence. 5. Confirm whether the company and subsidiaries operate in foreign investment prohibited/restricted sectors under the "Special Administrative Measures for Foreign Investment Access (Negative List) (2024 Edition)."
According to its prospectus, Tinci Materials is an innovation-driven new energy and advanced materials company specializing in comprehensive lithium-ion battery materials, daily chemical materials, and specialty chemical solutions for global clients. The company has vertically integrated production across key electrolyte raw materials, including LiPF6, LiFSI, additives, and lithium carbonate. It has expanded into cathode materials (including lithium iron phosphate) and battery adhesives (including PACK structural adhesives and binders), forming a comprehensive lithium-ion battery materials solution. The company is also developing advanced materials for emerging applications in autonomous driving, eVTOL, semiconductors, cutting-edge engineering, and AI thermal management.
Next-generation products include solid-state electrolytes, automotive electronics and semiconductor-specific adhesives/sealants, high-performance polymers (mainly PEEK and PI), efficient coolants, and flame-retardant materials. According to CIC data, as of June 30, 2025, Tinci Materials achieved self-sufficiency rates of 99.0% for LiPF6, 97.0% for LiFSI, 90.0% for DTD additives, and 100.0% for high-purity lithium carbonate, ranking first in the industry.
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