Ultium Cells LLC — FEOC Compliance Audit: Anode Active Materials

Stated vs. Observed | Graphite/Anode Scope Only | Last verified: 2026-05-13

Status Header

Facility	Ultium Cells LLC — Plant 1 (Warren, OH) / Plant 2 (Spring Hill, TN)
Owners	General Motors (50%) / LG Energy Solution (50%)
Announced capacity	~70 GWh combined
Chemistry	NMC 6:2:2 / graphite anode
Stated status	"On track for FEOC compliance across our battery supply chain in alignment with applicable regulatory timelines" (GM Q4 2025 earnings call, 2026-01-28)
Assessed status	DIVERGES — No public evidence of a named non-FEOC anode active material supplier as of 2026-05-13; customs records show FEOC-origin graphite at near-total volume through Q3 2025

The Ledger

2023-03-15

• Stated: GM announces Ultium Cells' commitment to full IRA compliance across its battery supply chain, including sourcing requirements, in a joint press release with LG Energy Solution (GM Newsroom, 2023-03-15).
• Observed: Treasury FEOC guidance not yet issued as of this date; no compliance obligation for anode active materials had been established. No qualification activity required or expected at this stage.
• Gap: Stated and observed align. Commitment made ahead of regulatory clarity; no divergence.

2023-12-18

• Stated: GM 2023 10-K (filed 2024-02-06, p. 34): "We are evaluating our battery supply chain for FEOC compliance and engaging with qualified suppliers to meet applicable requirements as they take effect."
• Observed: Treasury's December 2023 Final Rule established FEOC restrictions for anode active materials effective with 2027 model year vehicles. No Ultium Cells or LG Energy Solution press release naming a non-FEOC graphite or anode active material supplier appeared in trade press through end of 2023 (search of Benchmark Mineral Intelligence, Fastmarkets, and S&P Global Commodity Insights archives, conducted 2026-05-13).
• Gap: "Evaluating" and "engaging" describe process initiation. No named supplier, volume commitment, or qualification milestone disclosed in the filing. Consistent with a company in early-stage compliance planning rather than active qualification.

2024-04-23

• Stated: GM Q1 2024 earnings call (2024-04-23): CFO Paul Jacobson — "We continue to make progress on our FEOC compliance roadmap, including for anode materials, and we're engaged with the right partners to meet the timeline."
• Observed: Panjiva customs records for Ultium Cells LLC import activity, Q1 2024: approximately 3,600 metric tons of graphite and anode active materials received from Shanshan Co. Ltd. (Changsha, China) and BTR New Material Group (Shenzhen, China), country of origin China — both entities FEOC-covered under Treasury's definition. Volume consistent with near-total anode active material supply for both plants at reported production rates.
• Gap: Continued FEOC-origin imports are consistent with a company qualifying alternative suppliers in parallel while maintaining current production supply. Customs data confirms current sourcing is FEOC-covered but does not confirm or deny forward qualification status. "Progress on compliance roadmap" and "engaged with the right partners" are not inconsistent with this picture, but no named non-FEOC partner has been identified.

2024-08-14 / 2024-09-03

• Stated: No Ultium Cells, GM, or LG Energy Solution press release or earnings-call reference to a named non-FEOC anode active material supplier appeared in trade press through 2024-Q3. No public company response to peer qualification announcements identified as of 2026-05-13.
• Observed: Panasonic Energy announced qualification of Anovion Technologies (Hoosick Falls, NY) synthetic graphite for North American cell production (Panasonic press release, 2024-08-14). Samsung SDI confirmed an offtake agreement with Syrah Resources for natural graphite from Syrah's Vidalia, Louisiana facility (Syrah ASX filing, 2024-09-03). Both announcements named specific suppliers, volumes, and qualification milestones.
• Gap: Two of Ultium's direct peers in North American cell manufacturing publicly named non-FEOC anode suppliers in Q3 2024; Ultium named none. Status inferred from absence of announcement, not confirmed by company. Resolution requires a GM, LG Energy Solution, or Ultium Cells press release naming a non-FEOC graphite supplier with volume and qualification timeline.

2024-Q4 (job posting activity)

• Stated: No public company statement on anode supplier qualification staffing or activity in Q4 2024.
• Observed: LinkedIn job posting review conducted 2025-01-15: Ultium Cells posted zero open roles with titles or descriptions containing "anode," "graphite," "active material," or "supplier qualification" during Q4 2024. LG Energy Solution's Michigan Technical Center posted two roles for "Cell Material Qualification Engineer" in the same period; neither listing specified non-FEOC graphite as a scope item. Absence-of-evidence signal. Searched for: US-based anode qualification engineering roles consistent with domestic supplier onboarding.
• Gap: Ambiguous. Absence of US-posted qualification roles is consistent with either qualification work being managed through LG Energy Solution's Korean engineering organization (which would not appear in US job postings) or qualification not yet initiated at production scale. This entry cannot be weighted heavily without corroborating signal from LG Energy Solution Korea.

2025-02-11

• Stated: GM 2024 10-K (filed 2025-02-11, p. 41): "Ultium Cells is engaged with multiple potential suppliers of anode active materials outside the scope of FEOC restrictions. We expect to finalize supplier qualification in advance of applicable compliance deadlines."
• Observed: No named non-FEOC graphite supplier in any GM, LG Energy Solution, or Ultium Cells public disclosure through 2025-Q2. Benchmark Mineral Intelligence North American Anode Supply Tracker (April 2025 edition) lists Ultium Cells as having "no confirmed non-FEOC anode active material supplier" — the only major North American cell manufacturer in that category among the six tracked. No public disclosure of a named supplier, volume commitment, or qualification milestone as of 2025-05-13.
• Gap: "Engaged with multiple potential suppliers" and "expect to finalize" describe intent, not completion. Benchmark's independent tracker provides corroboration that qualification has not been publicly confirmed. The 10-K language is materially unchanged from the 2023 filing's "evaluating and engaging" formulation, despite two additional years of elapsed time.

2025-10-22

• Stated: As quoted above.
• Observed: Panjiva customs records, Q3 2025: Ultium Cells received approximately 4,200 metric tons of graphite and anode active materials from Shanshan Co. Ltd. and BTR New Material Group, country of origin China. Volume represents an estimated 85–90% of Ultium's anode active material consumption for the quarter, based on cell production rates disclosed in GM's Q3 2025 10-Q. No reduction in FEOC-origin graphite volume observable in customs data relative to Q1 2024.
• Gap: FEOC-origin imports at near-total volume in Q3 2025, combined with the explicit refusal to name a non-FEOC supplier on the earnings call, is consistent with a company that has not yet transitioned production supply. "Won't get into specific supplier names" confirms no public qualification announcement. With 2027 model year enforcement approximately 15 months from Q3 2025, the absence of a named supplier at this stage is observable and notable relative to peers who named suppliers 12–14 months earlier in their own qualification cycles.

2026-01-28 (most recent)

• Stated: GM Q4 2025 earnings call (2026-01-28): "We're comfortable with our FEOC compliance trajectory for anode materials given the 2027 model year enforcement timeline. We'll have more to say on supplier specifics when appropriate."
• Observed: Treasury's December 2024 notice confirmed 2027 model year as the effective enforcement date for FEOC anode active material restrictions. GM's stated timeline is consistent with the regulatory calendar. No named non-FEOC anode supplier in any public disclosure as of 2026-05-13.
• Gap: Stated and observed align on the enforcement date. "Comfortable with trajectory" is not inconsistent with a qualification process that is advanced but undisclosed. Whether qualification is complete, in final stages, or still in progress cannot be resolved from public data. No public disclosure of qualification status as of 2026-05-13.

Trajectory Assessment

Read as a time series, the ledger shows a gap that has not narrowed. Ultium's stated language has progressed from "evaluating" (2023 10-K) to "engaged with multiple potential suppliers" (2024 10-K) to "comfortable with trajectory" (Q4 2025 earnings call) — a sequence of increasing confidence unaccompanied by any observable qualification milestone across three years of entries.

Customs data is the clearest signal available: FEOC-origin graphite volume held at 85–90% of estimated consumption from Q1 2024 through Q3 2025, the last period with available records. No reduction is observable. Peer comparison shows the asymmetry widening: Panasonic and Samsung SDI named non-FEOC anode suppliers in Q3 2024; Ultium has named none as of May 2026.

The 2027 model year enforcement deadline leaves approximately 12 months of remaining runway from today. Industry-standard anode active material qualification timelines — from initial sample evaluation to production-volume approval — run 12 to 18 months under normal conditions, based on qualification schedules disclosed by Anovion and Syrah in their respective customer announcements.

The evidence supports two readings: qualification is materially complete but strategically undisclosed, with LG Energy Solution's Korean engineering organization managing the process without US-visible signals; or qualification is in late-stage evaluation, with the company relying on the remaining runway. The ledger cannot distinguish between them. A named non-FEOC supplier announcement with volume commitment, or customs records showing non-FEOC graphite shipments beginning, would change this assessment. Neither has appeared. If the current pattern holds through Q2 2026 without a named supplier announcement, the qualification timeline becomes difficult to reconcile with the enforcement calendar under standard industry assumptions.