The Zhitong Finance App learned that on August 14, the China Securities Regulatory Commission issued the “Notice on Requirements for Supplementary Material Filing for Overseas Issuance and Listing (August 10, 2026 to August 14, 2026)”. The International Division of the China Securities Regulatory Commission issued supplementary material requirements for a total of 8 companies. Among them, Tianhua Xinneng was requested to further explain whether the pricing of related transactions between the reporting period and the Ningde era was fair, whether there were any circumstances of transfer of benefits, etc. According to the Hong Kong Stock Exchange's disclosure on April 2, Tianhua Xinneng (300390.SZ) submitted a listing application to the main board of the Hong Kong Stock Exchange, with Huatai International and CMB International as co-sponsors.
The China Securities Regulatory Commission requested Tianhua Xinneng to provide additional explanations on the following matters. Lawyers carried out inspections and issued clear legal opinions:
1. Please further explain whether your company has built, is under construction, and whether the current fund-raising project is a “high energy consumption” and “high emission” project, and provide relevant evidence.
2. Based on circumstances such as solvency, etc., please explain whether the issuer's and subsidiary companies' major loans and external guarantees may cause major ownership disputes or changes in the company's controlling shareholder before and after the completion of the current offering.
3. Please provide additional information on the specific implementation of overseas investment, foreign exchange registration and other supervisory procedures involving the establishment of overseas subsidiaries by your company, and issue a concluding opinion on compliance.
4. Please provide additional information on the details of the related transactions between your company and the Ningde era during the reporting period, whether the pricing of such related transactions was fair, whether there was a transfer of benefits, and provide a clear basis.
5. Please further explain the details of all pending lawsuits and arbitration involving your company, whether the relevant circumstances will have a significant adverse impact on the company's future operations, whether they will constitute a material obstacle to this issuance, and whether the relevant circumstances have been fully disclosed.
6. Please further explain the necessity and rationality of your company's current listing in Hong Kong in conjunction with the fund-raising investment.
According to the prospectus, Tianhua Xinneng is a new energy technology enterprise, mainly engaged in R&D, production and sales of new energy lithium battery materials. The company's business is divided into three business segments, namely new energy lithium battery materials, anti-static ultra-clean technology products, and medical devices. According to Frost & Sullivan data, based on sales volume and revenue in 2025, Tianhua Xinneng is the largest battery-grade lithium hydroxide producer in China and the third largest battery-grade lithium hydroxide producer in the world. In the same year, Tianhua Xinneng was the fourth largest producer of battery-grade lithium compounds in China and the world. The company's core products, battery-grade lithium hydroxide and battery-grade lithium carbonate, are all core raw materials for manufacturing lithium batteries, and are widely used in NEV power batteries, energy storage systems, low-altitude aircraft and consumer electronics.