ABTC's announcement gives this workflow a commercial example
On October 1, American Battery Technology Company announced BIS approval for exports of up to $100 million of its recycled black mass under specified terms. This is the company's announcement, not a published copy of its license. This guide does not have the full license terms, approved counterparties, destinations or validity period. Its headline ceiling is not a standard limit for other recyclers. ABTC announcement distributed through GlobeNewswire.
Start with the actual BIS authorization
The BIS allocation order allows adjustments, exceptions and temporary licenses. A pending request does not provide relief unless BIS grants interim relief in writing. Recipients must comply with their approval's terms, and separate EAR obligations still apply. BIS temporary final rule, Supplement No. 1(c).
For your operating file, use a unique authorization ID and link the signed or issued approval. Record the approval type, BIS number, status, dates, responsible reviewer and related correspondence. Extract every condition into the review process before using the approval for a transaction.
Connect approval scope to the transaction
Create a permitted-scope record for each approved buyer, destination and material combination. Use stable IDs that also appear in the sales register. Record current physical location separately from the intended destination. An approval for one combination should not become a blanket permission for every buyer or shipment.
Keep supporting instructions beside the scope record. If the approval includes return obligations, processing restrictions, sublimits or reporting milestones, maintain a supporting schedule and check it as part of the transaction's conditions review.
Reserve capacity before release
Choose the valuation basis, units and event date specified by your approval. Record prior consumption before the workbook's starting date. Then distinguish consumed transactions from active reservations, so two planned shipments cannot each use the same remaining capacity.
For an approval with a value ceiling, the operating balance is the documented ceiling less prior consumption, recorded consumption and active reservations. Track quantity separately when the terms also impose a quantity limit. Use one consistent unit and document any currency conversion. Do not treat a blank ceiling as unlimited permission.
Keep DPAS, EAR and AES evidence together
Census describes four AES treatments based on DPAS and EAR license requirements. Its instructions address C30/C33, license numbers, separate commodity lines where both licenses apply, DPASNO for qualifying non-covered material and Schedule B rather than HTS. Read the Census AES instructions.
Link the authorization to the sales record and shipment-control record. Retain the accepted filing, ITN, filing date, license-line values, bill of lading, conditions evidence and release or hold record. Do not use an accepted filing alone as proof that every authorization term has been met.
Use a release review that exposes unfinished work
- PASS: the entered approval, scope, dates, capacity and conditions checks are complete.
- REVIEW: a required determination, record or evidence item is missing or uncertain.
- BLOCK: entered information shows inactive approval, an unapproved combination, dates outside the approval, failed conditions or insufficient capacity.
These are suggested operating controls. They are not government certifications or a substitute for assessing the full approval. The shipment must also clear its applicable sales and AES/EEI controls.
Put the records into a repeatable workflow
The DPAS Covered-Material Sales, Authorization & Evidence System links an authorization register and permitted-scope table to transaction controls, reserved and consumed capacity, AES/EEI evidence and monthly review. It retains domestic-sales controls for transactions that do not rely on documented relief.
Related DPAS guidance
Requesting adjustments and exceptions · Schedule B coverage · Monthly sales reconciliation · Black mass sales controls
Operational guidance as of October 1, 2026. Current allocation-order period: August 27, 2026 through August 27, 2027, unless changed. Confirm current BIS, EAR and filing requirements and your actual written approval. This article does not describe ABTC's undisclosed license terms or provide legal advice.