Wanted to share a deeper dive into the relevance of the latest IRA ruling on the FEOC impact to the 30D tax credits. Particularly the Sub Guidance, in relevance to Korean Battery Manufacturers.
"Under the excluded entity restriction, in order to be eligible for the section 30D credit, vehicles placed in service beginning in 2024 must not have batteries containing battery components manufactured or assembled by a FEOC. In addition, vehicles placed in service beginning in 2025 must have not batteries containing applicable critical minerals extracted, processed, or recycled by a FEOC."
https://www.whitehouse.gov/cleanenergy/clean-energy-updates/2023/12/01/treasury-doe-release-proposed-guidance-to-strengthen-domestic-supply-chains-for-batteries-and-electric-vehicles-ensure-the-u-s-leads-the-clean-vehicle-future/
The above rules out any tax eligibility for sg or anode, coming out of China by 2025, which is nearly all of it. Note (not all manufacturers will chase the tax credit) but a lot will, hence the reason they built in North America.
In relevance to this comany, LGES has 8 jointly owned and wholly owned North American plants coming online in the next 5 years. NVX JDA has been in place since June, 12 months qualification minimum has been underway for Anode.
Samsung SDI Mou in place since 2019, in Recent interview Chris stated "We are working closely with Samsung and Panasonic on the actual materials the will be using in their North American Battery plants". Again Samsung is a major committed player in the US with several plants and over 100GWh coming online in next 5 years. Panasonic is worthy to add to this list but, although not a Korean Manufacturer, is in the same boat & another with an MOU development agreement in place. Multiple plants in US & expanding in next 5 years.
FEOC timeline this year through Korean Media.
April 23: The U.S. Treasury Department announced detailed guidelines for subsidies for electric vehicles under the Inflation Reduction Act (IRA) on March 31 (local time). Many Korean analysts say that the detailed guidelines are not much different from what they expected. However, they are also devoid of specific provisions that directly or indirectly affect Korean battery makers, such as foreign entities of concern (FEOCs)
https://www.businesskorea.co.kr/news/articleView.html?idxno=112076
Sept 23: Anode materials like graphite also largely (90%) come from China. While efforts are underway to diversify imports from South America, Australia, and ASEAN regions, an overnight transition is unrealistic.In response, local companies have been urging the U.S. government to provide clarity on FEOC and address uncertainties. They’re calling for a clear definition of FEOC, grace periods for minerals heavily reliant on China, and detailed regulations that reflect the reality that fully excluding China isn’t feasible.During his visit to South Korea, U.S. Deputy Secretary of Commerce Don Graves held a private meeting with executives of leading Korean secondary battery companies such as LG Energy Solution, Samsung SDI, SK on, POSCO FutureM, SK ie technology, and Lotte Energy Materials on Sept. 22.During this meeting, Korean battery companies reportedly asked the U.S. side to quickly clarify the concept of FEOCs under the IRA, which might essentially put them on a trade ban list, to remove the uncertainties surrounding significant investments.출처 : Businesskorea(https://www.businesskorea.co.kr)
https://www.businesskorea.co.kr/news/articleView.html?idxno=202496
SEOUL, Dec. 2 -- The Seoul government on Saturday welcomed the release of proposed U.S. guidance on U.S. tax credits for electric vehicles (EVs), noting it will help remove uncertainties surrounding the 2022 Inflation Reduction Act (IRA).
Seoul said it will help diversify supply chains of critical minerals used in EV batteries, so that local manufacturers may avoid facing any disadvantage under the IRA.First Vice Minister of Trade, Industry and Energy Jang Young-jin made the remark in a meeting with representatives from top battery makers -- LG Energy Solution, SK On and Samsung SDI -- as well as officials from related organizations and government agencies.
https://en.yna.co.kr/view/AEN20231202001751320
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