Four Forces on China's Tier-2 Battery Producers

The price floor

LFP ESS cell spot (314 Ah prismatic) is trading at approximately RMB 0.36–0.40/Wh for Tier-1 and RMB 0.34–0.35/Wh for Tier-2 as of mid-May 2026, roughly 40% above the October 2025 trough of RMB 0.26/Wh (InfoLink; Energy-Storage.News, March 11, 2026). The first derivative is positive. More useful: the second derivative reversed in May. Price increases had been decelerating through March and April as cells plateaued near RMB 0.36/Wh. Then lithium carbonate breached RMB 200,000/MT and cell prices re-accelerated while system-level pricing held steady. Cathode inventory buffers that had insulated cell producers from input cost pass-through were exhausted by March. New production runs are priced against current lithium.

LFP prismatic for EV applications trades above ESS cell spot due to automotive qualification requirements and smaller batch complexity, but current EV-grade LFP cell pricing at the specificity this publication would trust is not available from named assessment sources in the May 2026 English-language data. NMC pricing is similarly opaque at the cell level. The dependent variable for two of the four forces below (GB 38031, MIIT campaign) is power battery pricing, and the reader should note this gap. What we can observe: CATL held 47.2% of China's EV battery installation market in April 2026 with 29.06 GWh installed (EnergyTrend), and the Tier-1/Tier-2 price gap visible in ESS (roughly 15%, with CALB quoting as low as RMB 0.34/Wh against CATL's ~0.40/Wh) is structurally present in power batteries as well, mediated by the same cost asymmetries.

That gap is where consolidation either happens or doesn't. The four forces below are widening it, narrowing it, or holding it open on different timelines, in different segments, with different reversibility. A single "consolidation is accelerating" narrative blurs the picture and leads to wrong timing on sourcing decisions. The forces need to be tracked independently.

Force 1: VAT export rebate phase-out

Status: Strengthening. The first step executed on schedule: rebate dropped from 9% to 6% on April 1, 2026. The second step, to 0%, takes effect January 1, 2027.

Mechanism. The rebate phase-out raises the effective cost of every exported cell by compressing the exporter's margin on CIF-delivered product. For a Tier-2 producer exporting LFP ESS cells at thin or negative domestic margins, the rebate was functioning as a cross-subsidy that made export volumes viable even when domestic pricing was below cost. Removing it forces a choice: absorb the margin hit, raise export prices and lose volume to competitors who can absorb it, or exit export markets. CATL's 2025 annual report shows gross margins of 23.84% on power battery systems and 26.71% on energy storage battery systems, with a group-level gross margin of 26.27%. BYD reported a group-level gross margin of 17.74% in 2025, with overseas operations at 28.1% (BYD does not report a standalone battery segment with separable margins). A Tier-2 producer operating at or below breakeven domestically cannot absorb what CATL treats as rounding error.

Timeline. April 2026 step is done. January 2027 step is seven months away. No legislative mechanism exists to reverse or delay the phase-out once enacted.

Segment scope. Both power battery and ESS. Every lithium-ion cell exported from China is affected regardless of end-use application.

Reversibility. One-way ratchet. Its defining property relative to the other three forces: it does not cycle with commodity prices, does not depend on enforcement discretion, and does not distinguish between compliant and non-compliant producers. It raises the floor cost of being a Chinese battery exporter on a fixed schedule.

Force 2: GB 38031-2025 compliance gate

Status: Strengthening, but narrower than the consensus narrative assumes. CATL certified April 29, 2025, per its public disclosure. BYD's Blade and Flash Charge Blade batteries reportedly passed testing by May 2025, per ChinaEVHome relaying BYD communications (not independently verified against the certification database). No public certification announcement from Gotion High-Tech, EVE Energy, CALB, Farasis, Svolt, or REPT Battero has been identified in English-language sources through May 23, 2026.

That silence is a data point. July 1, 2026 is 39 days away. Both CATL and BYD treated their certifications as competitive signals and publicized them prominently. The absence of equivalent announcements from Tier-2 producers admits two readings: certifications obtained but not publicized (unlikely given the signaling value), or certifications still in process. The second reading is more consistent with the evidence pattern.

Caveat, stated clearly: Chinese certification databases are not fully accessible in English. Absence of public announcement is not confirmed non-compliance. Tier-2 certification status is opaque as of this writing. July 1 enforcement will generate observable compliance data.

Mechanism. GB 38031-2025 functions as a market-access gate for power batteries only. A producer without certification cannot submit new model type approvals after July 1, 2026. Existing models have until July 1, 2027. The standard does not directly affect cell pricing, but it constrains the addressable market for uncertified producers: they can continue selling existing models for twelve months but cannot compete for new vehicle platform contracts. For a Tier-2 producer whose power battery business depends on winning new OEM design-ins, this is a revenue ceiling that tightens over time.

Timeline. July 1, 2026 (new type approvals). July 1, 2027 (existing models). No signal of extensions or informal grace periods has appeared.

Segment scope. Power batteries only. ESS cells are explicitly outside the standard's scope. This scoping distinction matters more than any other regulatory detail in the current environment: GB 38031-2025 is a power battery consolidation mechanism. It does not touch ESS producers.

Reversibility. The standard is permanent. Certification, once obtained, is durable. The consolidation effect is front-loaded into the 2026–2027 compliance window.

Force 3: MIIT anti-competition campaign

Status: Stable in cadence, weakening in credibility. Three symposia in five months (November 2025, January 2026, April 9, 2026). No binding enforcement actions, penalties, capacity restrictions, or regulatory orders against any named battery producer have been identified in English-language sources through May 23, 2026. The only post-April enforcement action found was a joint notice on waste battery recycling, a distinct regulatory domain that should not be conflated with production-side anti-competition enforcement.

Mechanism. The campaign operates through indirect levers, as characterized by Gasgoo's analysis (February 2026): rebate cancellation (the VAT phase-out, already operative), capacity warnings (soft signaling, not shutdown orders), and quality supervision (consistent with GB 38031-2025 as a compliance gate). Transmission to cell price is indirect and slow. The campaign establishes a rhetorical floor under pricing by signaling that below-cost dumping is politically disfavored. It does not establish a binding price floor. No producer has been sanctioned for pricing behavior.

The MERICS assessment that the government is not planning a harsh crackdown on overcapacities holds through May 2026. Each additional symposium without binding action erodes the campaign's credibility as a consolidation force. The cadence is regular; the teeth are absent.

Timeline. No scheduled enforcement date. The symposium cadence (roughly every two months) may continue indefinitely without producing binding outcomes.

Segment scope. Both power battery and ESS. The January 2026 symposium explicitly named both sectors.

Reversibility. Fully reversible. A rhetorical campaign can be abandoned or intensified at any time. It imposes no sunk costs on producers and creates no compliance obligations. The weakest of the four forces, and the most discretionary.

Force 4: Lithium carbonate spike

Status: Strengthening in the short term, cyclical in structure. Battery-grade lithium carbonate reached RMB 200,500/MT on May 13 (InfoLink, corroborated by Trading Economics futures data), a two-year high, up from RMB 73,550/MT in October 2025. Proximate causes are supply-side: Jiangxi mining permit freeze, Zimbabwe export suspension.

Mechanism. Rising lithium carbonate costs compress margins for all cell producers, but the compression is asymmetric. CATL, with gross margins of 23.84% on power batteries and 26.71% on ESS (2025 annual report) and a new RMB 30 billion mining subsidiary approved by the board in April 2026 as a path to vertical integration into raw materials, has both margin buffer and structural insulation. The mining subsidiary is an announced initiative, not an operating one; its effect on CATL's input costs is a 2027–2028 story at earliest. But the existing margin buffer is operative now. A Tier-2 producer buying spot lithium carbonate at RMB 200,000/MT while selling cells at RMB 0.34–0.35/Wh faces arithmetic that does not close.

The spike amplifies margin pressure that already exists from the structural Tier-1/Tier-2 price gap and the VAT ratchet. A Tier-2 producer that was marginally viable at RMB 80,000/MT lithium carbonate becomes unviable at RMB 200,000/MT. The spike accelerates the timeline on which the structural forces produce observable distress.

Timeline. If the Jiangxi permit freeze resolves in Q3 2026, lithium carbonate could reverse toward RMB 100,000/MT by year-end. If it doesn't, the elevated cost environment persists into 2027 and compounds with the January VAT step-down.

Segment scope. Both power battery and ESS.

Reversibility. Cyclical and reversible. The critical distinction from the VAT ratchet. The lithium spike is the force most likely to produce near-term Tier-2 distress and the force most likely to reverse. Confusing a cyclical amplifier with a structural shift leads to wrong conclusions about consolidation durability.

Force	Status	Segment scope	Key date	Reversibility
VAT rebate phase-out	Strengthening	Both	Jan 1, 2027 (→0%)	One-way ratchet
GB 38031-2025	Strengthening (narrow)	Power battery only	Jul 1, 2026 / Jul 1, 2027	Permanent standard
MIIT campaign	Stable / weakening	Both	No enforcement date	Fully reversible
Lithium carbonate spike	Strengthening (short-term)	Both	Jiangxi resolution (Q3?)	Cyclical

What holds the overcapacity in place

These four forces act on a market structure that resists consolidation by design.

CRU Group data shows non-Tier-1 battery production grew 146% in the period under review, a rate not explained by demand growth alone. The gap between CATL's reported utilization rate of 96.9% (2025 annual report) and the industry average of approximately 50% (Mordor Intelligence estimate, 2024; the most recent publicly available industry-wide utilization figure, which itself is a signal about data opacity) is the single most important structural number in the Chinese battery market. Roughly half of installed capacity outside CATL is running at rates that cannot sustain profitability at current cell prices.

Why does that capacity persist? Provincial incentive structures. CRU's analysis of dynamics in provinces like Guangxi documents a pattern in which local governments provide land, tax incentives, and direct subsidies to attract battery manufacturing as an industrial development strategy. The incentive is job creation and GDP contribution, not return on invested capital. A Tier-3 producer running at 30% utilization but employing 2,000 people in a provincial development zone is meeting its sponsor's objective even when it is failing its investors'. The whitelist system, the administrative mechanism that could in principle force exits by removing underperforming producers from approved supplier lists, has not been materially updated to cull non-viable capacity (CRU Group, analytical assessment). The whitelist's stasis is a policy choice that sustains the overcapacity the MIIT campaign rhetorically opposes.

Sourcing limitation, named explicitly: Provincial incentive structures are structurally opaque in English-language sources. CRU's analytical pieces are the best available window. We can describe the mechanism and cite the output data (146% non-Tier-1 production growth), but we cannot observe specific subsidy flows or their durability at the provincial level.

The Q1 2026 financials from observable Tier-2 producers show compressed margins, not distress. EVE Energy reported Q1 revenue of RMB 20.68 billion, up 61.6% YoY, with net profit of RMB 1.45 billion, up 31.4%. Profit growing at half the rate of revenue is worth watching but is consistent with the rising lithium carbonate cost environment, not a distress signal. Gotion High-Tech reported FY2025 revenue of RMB 45.07 billion (+27.4% YoY) and net profit of RMB 2.38 billion (+97.5% YoY), though a Q4 2025 net loss of RMB 150 million flags quarterly-level margin fragility when lithium costs were rising sharply. CALB's Q1 revenue and profit rose (detailed segment financials not available in English-language sources). Mid-tier players with growing revenue, compressing margins, and expanding capacity: EVE announced a 60 GWh energy storage battery base in Fujian (RMB 6 billion investment), and five leading producers including EVE and CALB established nine new companies with combined registered capital exceeding RMB 3.3 billion since March 2026. The consolidation the four forces are supposed to produce has not yet arrived at this tier.

Below them, the picture is less clear. No Q1 2026 financial distress reporting was found for Farasis, REPT Battero, Great Power, or DFD New Energy. REPT Battero was present at CIBF 2026 (May 13–15) with a 588 Ah product platform announcement, confirming active investment in next-generation cells. English-language coverage of these producers is structurally thin. The absence of distress signals could mean no distress exists, or it could mean provincial support is successfully suppressing visible signals, or it could mean we cannot see it from here. I cannot resolve this and will not pretend otherwise.

Where the forces compound and where they cancel

The VAT ratchet versus provincial life support. The ratchet raises the cost of being an exporter. Provincial incentives lower the cost of being a domestic producer. For a Tier-2 producer that exports heavily, the ratchet wins: margin arithmetic deteriorates on a fixed schedule regardless of provincial support. For a Tier-2 producer selling primarily into the domestic market, provincial incentives can offset the ratchet's indirect effects for longer. Provincial incentives are currently winning. The Q1 data shows no observable Tier-2 exits. The 146% non-Tier-1 production growth has not reversed. But the ratchet is cumulative, and the January 2027 step-down will test whether provincial budgets can absorb the full loss of export margin subsidy for their sponsored producers.

GB 38031-2025 versus the ESS escape valve. The compliance gate constrains the power battery segment. It does not touch ESS. A Tier-2 producer that fails or delays GB 38031 certification can redirect capacity toward ESS, where the compliance burden is lower and demand growth is strong (InfoLink projects 801 GWh global cell shipments in 2026, with ESS as the core growth driver). The interaction worth tracking: GB 38031 consolidates the power battery market but may inadvertently flood the ESS market with displaced Tier-2 capacity, intensifying price competition in the segment where the VAT ratchet is the binding constraint. This escape valve is prospective, not yet operative. It depends on July 1 certification data. If most Tier-2 producers clear the gate, the valve stays closed. If several do not, it opens, and ESS pricing comes under pressure from capacity that has nowhere else to go. The 39-day window to July 1 is the period in which this tension resolves from prospective to observable.

The lithium spike versus the MIIT campaign. The spike raises input costs and compresses margins, which should accelerate exits. The campaign signals that the government wants orderly consolidation, not chaotic exits. The spike is currently dominant: it is producing real margin compression (visible in EVE's profit-to-revenue growth gap, in Gotion's Q4 loss, in the exhaustion of cathode inventory buffers), while the campaign has produced three symposia and zero penalties. If the spike produces a wave of Tier-3 defaults in provinces that cannot sustain their subsidies, the political pressure to intervene increases. The campaign's rhetorical floor becomes harder to maintain if the market is producing the disorderly outcomes it was designed to prevent.

Durability assessment

The current price floor of RMB 0.34–0.36/Wh for Tier-2 LFP ESS cells is durable for the next six months, conditional on two variables.

First, lithium carbonate. If the Jiangxi permit freeze resolves in Q3 and lithium reverses toward RMB 100,000/MT, input cost pressure eases, Tier-2 margins stabilize at thin but survivable levels, and the price floor holds or softens modestly. If lithium stays above RMB 180,000/MT into Q4, the January 2027 VAT step-down arrives into an already margin-negative environment for the weakest Tier-2 exporters.

Second, GB 38031 enforcement. July 1 will reveal which Tier-2 producers have certification for new power battery models. Widespread non-certification tightens the power battery segment faster than consensus expects and pushes displaced capacity into ESS, compressing ESS margins even as input costs push them up.

Assessed base case: Jiangxi resolves in Q3 (mining permit freezes in China have historically resolved within 6–12 months), lithium moderates toward RMB 120,000–140,000/MT by Q4, and the softer scenario prevails. Tier-2 producers survive 2026 with compressed but positive margins. The harder scenario (lithium sustained above RMB 180,000/MT compounding with the January 2027 VAT step-down) is the tail risk, not the central case, but it is the scenario that produces the exits everyone is pricing in prematurely. The next observable data point is July 1. Thirty-nine days.