The STA's August 27 Q&A drew the taxable-object line two business days before the September 1 consumption-tax start. Battery clusters assembled from purchased cells are taxable at 2%. Complete energy storage systems integrating cluster, electrical, thermal, fire protection, and control systems are classified as "complete set of power equipment" and fall outside the tax. Semi-solid-state batteries do not qualify for the solid-state exemption.
The deduction mechanism has a practical constraint worth pricing into September quotes: upstream consumption tax paid is deductible only against invoices dated September 1 or later, with a maintained deduction record and platform confirmation. PwC flagged in July that when the voucher arrives after the assembler's liability triggers, the timing mismatch becomes a working-capital cost absorbed more acutely by contract assemblers than by vertically integrated producers.
Separately, SMM terminated three pack-price series on August 28, citing product customization that made representative pricing indefensible. The measurement infrastructure is adjusting alongside the regulatory framework.
Taxable from Sep 1 (2%): Battery clusters from purchased Li-ion cells; semi-solid-state batteries (no solid-state exemption)
Not taxable: Complete ESS with integrated electrical, thermal, fire protection, and control systems
Exempt through Dec 31, 2028: Sodium-ion, solid-state, fuel cells — requires national-standard test report from qualifying institution
Deduction requires: Special VAT invoices or tax-payment docs dated Sep 1+; maintained deduction record; electronic platform confirmation
Rate schedule: 2% from Sep 1 2026; 4% from Sep 1 2027
Export: No consumption-tax rebate on packs embedded in exported NEVs; mixed domestic/export lines require deduction reversal on export-allocated materials
Sources: STA Q&A No. 3 (Aug 27); MOF/GAC/STA Announcement No. 20 (Jul 16); STA Announcement No. 16 (Jul 31); PwC China Tax Advisory (Jul 24). English-language relay via EnergyTrend Aug 28.