New EV Tax Credits

While all of Recurrent's attention up to this point has been on the used EV tax credits included in the Inflation Reduction Act, there are many substantial changes to the new EV tax credits. The bill has been heralded as an expansion to the existing incentive scheme since it removes the 200,000 vehicle cap for manufacturers, but adds new requirements and restrictions.

In addition to removing the 200,000 vehicle sales cap, allowing Tesla and GM to once again receive the tax credit, other changes include:

• New MSRP limits on eligible cars ($55K for cars, $80K for trucks/SUVs)
• Income limits for households ($150K for single filer, $300K for joint)
• Final assembly must be in the US
• Sourcing requirements for battery materials and components - for vehicles placed in service after April 18, 2023
• Starting in 2024, credits can be applied at the time of purchase, with the tax offset going directly to the dealer. Read more about this change.
• Update 12/1/23 Starting in 2024, there are eligibility restrictions based on manufacturing, assembly, or processing of EV parts in a Foreign Entity of Concern, which the Department of Energy has tentatively defined. These rules state that "an eligible clean vehicle may not contain any battery components that are manufactured or assembled by a FEOC, and, beginning in 2025, an eligible clean vehicle may not contain any critical minerals that were extracted, processed, or recycled by a FEOC."

A list of car manufacturers who have applied for and been approved for the Clean Vehicles credit can be found on the IRS website. Specific VINs need to be checked to confirm final assembly location on the Department of Energy website.

You can see the full list of vehicles that meet the newest battery mineral and component requirements at fueleconomy.gov. Filter the table by "placed in service after April 18."

The Critical Mineral and Battery Component Requirements

For vehicles "placed in service" (delivered to the taxpayer) after April 18, 2023, there are two clauses that render a vehicle eligible for the full $7500 credit. Each one is binary and worth $3750. This means that a vehicle may get a $7500 credit, or $3750, or nothing. It is entirely based on the percentage of battery components and materials that are sourced in the US, or countries with a free trade agreement. The required minimum percentage increases every year. This clause was included to spur American production of battery and clean-tech. reduce reliance on foreign suppliers, and reduce the risk of future supply chain disruptions.

What does this mean for the future of EVs?

Since the percentage of material that must meet these criteria ramps up over the next five years, companies are going to have to carefully revamp their supply chains and partnerships if they want to be eligible. 

This has caused a flurry of investment into US factories to process battery critical minerals and lithium reserves in North America. It also productizes lithium ion battery recycling, since that will be a way to turn ineligible, internationally-sourced materials into eligible, domestic supply. This act may be the catalyst to kick off the EV battery recycling industry in earnest.

What does this mean today?

As of the date that the Inflation Reduction Act was signed, August 16, 2022, some changes were immediate, and some were delayed until January 1, 2023. The critical mineral and battery sourcing requirements will go into effect when they are legislated.

The Alternative Fuels Data Center has a list of all EVs with final assembly in North America and both Department of Energy and the NHTSA provide a free VIN decoder that shows assembly location for a specific car.

Why the change?

A lot of Biden’s electrification investments have boiled down to competing with China on trade and manufacturing. Although most of the lithium, cobalt, and nickel that passes through China has been sourced elsewhere, China has established itself as the dominant player in the world EV supply, producing around 75% of the world’s materials. Meanwhile, under 10% of the lithium cells in EVs are made in the US. Astute observers have noted the manufacturing and production discrepancy between the two countries and have expressed anxieties that growing EV adoption could bolster China’s economy at the expense of our own. 

Senator Manchin, West Virginia senator and longtime climate legislation holdout, explains why he is intractable about the critical minerals and battery component requirements: "Tell (automakers) to get aggressive and make sure that we're extracting in North America, we're processing in North America and we put a line on China…I don't believe that we should be building a transportation mode on the backs of foreign supply chains. I'm not going to do it."

Another component of the new tax credits is a nod to American manufacturing. By requiring final assembly to be in the USA, the act invests in and stimulates our manufacturing sector. The original Built Back Better plan included language about American manufacturing, as well. 

Who wins? Who loses?  A changing picture.

When we think about who comes out on top with this new incentive scheme, we need to consider not just battery components and critical mineral sourcing, but the price cap, as well.

Back in August 2022, a Reddit user shared a spreadsheet with bets about winners and losers, showing that GM and Tesla come out on top, based on assumptions about current day supply chains and pricing. We translated a portion of it here.

Another analysis puts the number of EVs still eligible under the new plan at a whopping 12, while other estimates say that no one would be qualified under the new rules today. GM, who has been shoring up EV manufacturing and assembly in the US and generally supports the spirit of the bill, concedes that “some of the provisions are challenging and cannot be achieved overnight.” Rivian has also been vocal about their concerns with the new incentives, asking that the “final package must extend the transition period.”

Abby Wulf, director of the Center for Critical Minerals Strategy at the nonprofit Securing America’s Future Energy, called the bill’s mineral content requirements “ambitious” and said that the bill may “help to make automakers realize how serious it is that they can’t just rely on unreliable supply chains.” However, researchers worry that the limits, as set, are unreasonable and will effectively mean that the tax credit is unusable for the near future.  

Even if the final bill sees the transition period extended and the timeline softened, the real winners may be the climate. The benefit to including the battery component and critical mineral stipulation is that it encourages recycling and reuse of EV parts that are quite carbon intensive and politically treacherous to acquire. By building value into recycled components and materials, you force an incentive on an industry that might otherwise fail to develop. As we’ve written elsewhere, producing batteries is an extractive and exploitative process. And lithium ion battery recycling is still a ways away from generating revenue. Whatever its final form, this bill may help.

Additional Federal Support for EV Adoption

The federal government has been working to support the adoption of low and zero emissions vehicles as part of its renewed commitment to lowering national carbon emissions and realigning with the Paris Accord and global climate goals. 

In addition to the Inflation Reduction Act, there has been ongoing funding and legislation for the electrification of passenger transportation. This is a running list of measures this administration has taken: 

1. Bipartisan Infrastructure Law included many points related to transportation electrification and supporting the infrastructure for an electrified fleet of vehicles. It prioritizes connecting rural and underserved communities to chargers through a network of grants that total $2.5 billion.
2. A subsidiary program is the National Electric Vehicle Infrastructure (NEVI) Formula Program, which is a joint effort between the Department of Transportation and the Department of Energy. It commits $5 billion to build out a federal charging network by building alternative fuel corridors in every state and enforcing charging standards across the country. States can apply for funding each year. 
3. The Bipartisan Infrastructure Law also established a Joint Office of Energy and Transportation, uniting the two federal departments. More information on this effort is at https://driveelectric.gov/
4. CHIPS and Science Act - Funding for scientific research that supports the clean energy transition, and investment to onshore semiconductor production. This includes $200 billion for scientific research, a proposed $80 billion a year to accelerate zero-carbon energy transition, funding to develop and deploy technology that will help catalyze a 50% reduction in global emissions, much of which is still in early prototype stage, $20 billion Directorate for Technology to accelerate technology from prototype to mass market in the US and avoid losing critical technology production to foreign countries, $12 billion in new research & development for the Department of Energy, and additional billions to upgrade federal defense and energy research institutes, including the National Renewable Energy Laboratory, the Princeton Plasma Physics Laboratory, and Berkeley Lab
5. Department of Energy's EVs4ALL program which has invested $45 million to develop faster charging batteries 
6. The Joint Office of Transportation and Energy also established the Federal Advisory Committee Act Electric Vehicle Working Group

Read more about federal programs.