That starts to explain why there's a bit more traction on E25 making announcements. The FEOC is happening but there is just a "temporary" exclusion from needing to determine compliance with them until 2027.
On 3 May 2024 the US treasury department released their final determination in relation to the Foreign Entity of concern rules. They confirmed the expected rule that product would need to be traced, including the battery components. An exemption was granted for FEOC considerations until 2027. With the rules confirmed, decisions pendent on this confirmation start to occur.
My interpretation is that this creates a practical date of mid-late 2026 when new EV battery sources need to be commissioned. If a battery for an EV was made in late 2026 and put into an EV which was sold in 2027, to be eligible in 2027 they would need to pass the FEOC test. If they use Chinese produced HPMSM in a NCM style battery like NCM811, they wouldn't pass that test. If they go for higher density LMFP, they will need eligible Manganese. This new supply source is needed in just over 2 years. The could make LFP batteries for EV's but that reduces the range and for the American market range will be important to many.
This bit confirms the scale of the incentives. Yep only 100k of EV's created a $700m payment. By 2027 there are forecasts that the US EV market could be 2m vehicles per year. If even half of those were eligible vehicles to eligible customers the US treasury is making payments of US$7.5b that year. That interest should help a funding solution for critical minerals that will continue access to that product discount.
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