Regarding Rob Mauer's doubts regarding the application of the inflation reduction act 2022 to 4680 batteries (cells and/or packs) manufactured by Tesla, this is my interpretation of
the Bill.
I believe the following is applicable:
‘‘(4) SALE OF INTEGRATED COMPONENTS.—For purposes of this section, a person shall be treated as having sold an eligible component to an unrelated person if such component is integrated, incorporated, or assembled into another eligible component which is sold to an unrelated person.’’.
(emphasis mine)
The main question Rob points to is: "
Does a completed Tesla vehicle fall into the definition of "another eligible component"?".
The section lists the definition of eligible component:
‘‘(c) DEFINITIONS.—For purposes of this section— ‘‘(1) ELIGIBLE COMPONENT.— ‘‘(A) IN GENERAL.—The term ‘eligible component’ means— ‘‘(i) any solar energy component, ‘‘(ii) any wind energy component, ‘‘(iii) any inverter described in subparagraphs (B) through (G) of paragraph (2), ‘‘(iv) any qualifying battery component, and ‘‘(v) any applicable critical mineral.
The meat and potatoes for 4680's is the
"(iv) any qualifying battery component".
The Bill defines this as:
‘‘(5) QUALIFYING BATTERY COMPONENT.— ‘‘(A) IN GENERAL.—The term ‘qualifying battery component’ means any of the following: ‘‘(i) Electrode active materials. ‘‘(ii) Battery cells. ‘‘(iii) Battery modules.
The latter seems relevant:
‘‘(iii) BATTERY MODULE.—The term ‘battery module’ means a module— ‘‘(I)(aa) in the case of a module using battery cells, with 2 or more battery cells which are configured electrically, in series or parallel, to create voltage or current, as appropriate, to a specified end use, or ‘‘(bb) with no battery cells, and ‘‘(II) with an aggregate capacity of not less than 7 kilowatt-hours (or, in the case of a module for a hydrogen fuel cell vehicle, not less than 1 kilowatt-hour).
To compress this last definition, an eligible battery module is a module that either uses individual cells or not, but has an aggregate capacity of <7kWh.
The structural battery pack could be interpretated as a battery module in the sense of this section of the Bill, if you ask me. This structural battery pack, which just holds the cells in place, is part of the car which is then sold to an unrelated person.
Of course I could be entirely wrong, in which case the reason for the exclusion of in-house-cell-manufacturing-car-makers would be to not let them have double credits. The Bill could aim for a company to either take advantage of the EV tax credit (like Tesla), or the advanced manufacturing goods. (Implying that the EV credit is sufficient subsidy to the car maker to produce cells should they want to).
I don't know if this last makes sense since I haven't compared the dollar amounts a vehicle manufacturer would receive (directly or indirectly) from either the EV credits or the advanced manufacturing section of the Bill. (I know the EV credit goes to the customer, but the manufacturers can increase their prices by this amount pretty much).
I'm sure the Tesla lawyers already have their answer. If not they're on the phone with Congress as we speak.
).
