Approximately 700–900 GWh of US battery cell manufacturing capacity is announced, planned, or under some stage of development, depending on which industry tracker you use and how generously you count. The volume a procurement team can contract against today, with compliance documentation sufficient for a clean vehicle credit or a bankable ESS offtake, is a small fraction of that figure. The gap is widely acknowledged in aggregate. Its practical cost accumulates in specifics: qualification resources allocated against facilities that aren't where they appear to be, contracts drafted against capacity that has not cleared the compliance thresholds the credit requires, tariff and credit exposure that surfaces after commercial commitment. The ladder below defines twelve sequential evidence states, each specified by the minimum public evidence that places a facility there and the specific procurement risk that remains open until the next rung clears. Facilities typically clear rungs in sequence, but a named customer commitment or supply agreement can precede production start. That does not eliminate the production, yield, and compliance evidence requirements below it. The ladder defines the full evidence set required for contractability. Apply it to any facility; the open risks will be apparent from the gaps.
The Twelve Rungs
Rung 1 — Announced. Evidence: public statement of intent to build, expand, or convert a facility, with a named location or region. Press release, MOU, or executive statement qualifies. Open risk: No capital committed. Announcement-to-construction attrition in US battery manufacturing has been severe since 2022; E2's tracker counts 54 project cancellations, closures, or downsizings year-to-date through May 2026 alone. No supply probability can be assigned.
Rung 2 — Sited. Evidence: land acquired or leased, specific address identified. County property records, SEC filings referencing site acquisition costs, or state incentive agreements naming a parcel. Open risk: Site control does not imply permits, utility interconnection, or construction timeline.
Rung 3 — Permitted. Evidence: local building permits filed, state environmental review (or NEPA review for federally funded projects) completed, air quality permits issued, or stormwater/industrial discharge permits granted. State incentive agreements often condition disbursement on named permit milestones, making incentive-tracker filings a secondary evidence source. Open risk: Permits expire. The gap between permitted and breaking ground has widened as financing conditions tightened through 2025–2026.
Rung 4 — Under Construction. Evidence: foundation poured, structural steel erected, or equipment supplier contracts disclosed in filings. Construction loan drawdowns, state incentive milestone payments tied to construction progress, or dated satellite/site imagery. Open risk: Scope reductions, phase deferrals, and JV restructurings can occur mid-build. Equipment delivery is separate from building shell completion.
Rung 5 — Equipped. Evidence: major production equipment installed. Dry room or clean room completion disclosed. Equipment supplier confirmations or company filings referencing installation milestones. Open risk: Installed equipment still requires qualification. Electrode coating, cell assembly, and formation/aging lines need months of calibration. Chemistry or format changes (NCA to LFP, pouch to prismatic) may require re-equipping lines previously installed for a different product.
Rung 6 — Commissioned. Evidence: lines energized, engineering samples or test-production cells confirmed. Company disclosure of "first cell off the line" or equivalent milestone. Open risk: Engineering samples precede commercial product by months of yield optimization. Yield at commissioning is typically far below nameplate. No customer has accepted product.
Rung 7 — Producing. Evidence: commercial production started, with at least one output milestone disclosed. Acceptable forms include an earnings call reference to production commencement with a date, a press release citing units produced or a production-start milestone, or a state incentive payment triggered by a production-commencement condition. Open risk: Production rate and yield are unknown. A facility producing at 10% of nameplate is producing. The procurement question is volume reliability at the rate and quality a contract requires.
Rung 8 — Customer-Shipping. Evidence: named customer receiving product, confirmed by either producer or customer in a filing, earnings call, or press release. Open risk: Shipment does not imply acceptance. Automotive and utility-scale ESS qualification processes involve months of incoming inspection, module/pack-level testing, and field validation. A facility shipping to a customer who has not formally qualified the product is shipping on approval, not on contract.
Rung 9 — Yield-Disclosed. Evidence: output rate, capacity utilization, defect rate, or quality metric publicly reported at the facility level. Open risk: Yield disclosure without compliance documentation leaves the buyer exposed on credits and tariffs. A facility producing at high yield but unable to demonstrate MACR, PFE, or FEOC compliance produces cells that may not qualify for clean vehicle credits or may face tariff exposure.
Rung 10a — 45X / MACR Filed. Evidence: facility-level Section 45X advanced manufacturing production credit claimed in a tax filing, or MACR calculation disclosed or referenced in SEC filings. MACR safe harbor tables remain unpublished as of July 10, 2026. Mechanics are covered in the policy section of this issue. Open risk: IRS may challenge the filed calculation. Without safe harbor tables, every MACR filing carries methodology risk.
Rung 10b — PFE / FEOC Compliance Filed. Evidence: facility-level PFE or FEOC compliance status filed with Treasury or disclosed in SEC filings. This requires tracing battery components and critical minerals through the supply chain to demonstrate no prohibited foreign entity content above the applicable threshold. Mechanics are covered in the policy section. Open risk: PFE/FEOC thresholds tighten on published schedules (the FEOC graphite exemption expires December 31, 2026). A facility compliant today may not be compliant next quarter without supply-chain changes.
Rung 10c — Tariff-Origin Documented. Evidence: country-of-origin documentation sufficient for the applicable tariff regime, including USMCA qualification for Canadian-produced cells or Section 301/Section 232 tariff classification for components. Open risk: Tariff regimes shift. Origin documentation that satisfies current rates may not satisfy rates announced but not yet effective.
Rung 11 — Qualification-Confirmed. Evidence: customer or independent third-party qualification documented in a filing, customer earnings reference, or supplier qualification letter. In automotive: PPAP or equivalent. In ESS: bankability assessment or EPC/developer qualification. Open risk: Qualification is customer-specific and chemistry-specific. A facility qualified for one customer's NCA pouch cells requires a separate qualification cycle for a different customer's LFP prismatic cells.
Rung 12 — Contractable. Evidence: the facility clears all prior rungs for the specific chemistry, format, and compliance pathway the buyer requires. A supply agreement with defined volume, pricing, quality, and compliance terms can be written against publicly supportable evidence. Open risk: Residual risks are commercial (pricing, allocation priority, force majeure) rather than evidentiary. The facility's existence as supply is established. The remaining questions are terms.
Four Facilities Placed on the Ladder
Placements below use only publicly verifiable evidence as of July 10, 2026. Where status is inferred from indirect signals, the inference is stated. Negative-evidence claims (no filing found, no disclosure found) cover only the public sources checked and should not be read as proof that nonpublic workpapers, qualification packets, or compliance filings do not exist.
| Facility | Chemistry / Format | Rung | Key Evidence | First Missing Rung |
|---|---|---|---|---|
| NextStar, Windsor | LFP pouch | 7 (approaching 8) | Commercial production Nov 2025; 1M cells by Feb 2026 | 8: confirmed customer shipment |
| SK Commerce, Georgia | NCM (BESS conversion TBD) | 6 (regressed) | WARN layoff Mar 2026; no replacement customer disclosed | 7: production under current customer |
| StarPlus, Kokomo (NCA EV) | NCA | ~6 (status uncertain) | Line conversion to LFP underway since Q4 2025 | 7: current NCA production undisclosed |
| StarPlus, Kokomo (LFP ESS) | LFP | 5 | Equipment conversion in progress; mass production expected Q4 2026 | 7: LFP commercial production start |
| LGES Lansing (existing ESS) | LFP pouch/prismatic | 7 | Listed "In Operation" in Q1 2026 deck | 9: facility-level output or yield |
| LGES Lansing (Tesla line) | LFP prismatic | Pre-7 (Rung 8 evidence) | $4.3B Tesla supply agreement; production launching 2027 | 7: production start |
| Ford BlueOval SK, Kentucky | — | — | Audited separately in this issue | — |
NextStar Energy, Windsor, Ontario — Rung 7, Approaching 8
LG's June 26, 2026 release confirms NextStar began commercial cell production in November 2025, reached one million cells by February 2026, and started production on a new battery pack line on June 25, 2026. Stellantis is the JV partner and presumed offtake customer. LGES's Q1 2026 earnings deck lists Windsor as "In Operation" under North American ESS capacity and identifies LFP pouch products, but provides no facility-level output, yield, or compliance data. No shipment volumes, acceptance confirmations, or customer qualification disclosures were found in LG or Stellantis public filings checked through Q1 2026 reporting. No public 45X-equivalent Canadian production credit claim, USMCA-origin qualification, or MACR-related disclosure was found in the same filings. Missing for Rung 8: confirmed customer shipment in a filing. Missing for Rung 9: any disclosed output rate, utilization, or yield metric after the February 2026 million-cell milestone.
SK Battery America, Commerce, Georgia — Rung 6 (Regressed)
Commerce was previously producing and shipping NCM cells to Volkswagen and Ford. The March 2026 WARN-driven layoff of 958 workers, approximately 37% of the workforce, and the company's statement that it was pursuing future customers including in BESS, is the most recent facility-level evidence found. No subsequent SK Innovation or SK On quarterly disclosure checked through Q1 2026 reporting updates Commerce production volumes, names a replacement customer, or confirms BESS conversion progress. SK On reported negative KRW 349.2 billion operating profit in Q1 2026 at the segment level, with no Commerce-specific breakout. No Q2 2026 SK Innovation/SK On earnings material was posted on the public earnings page as of July 10, 2026. The facility is equipped and was previously commissioned, but the loss of its disclosed customer base and the absence of a replacement effectively regresses it. Evidence states require ongoing confirmation. Missing for Rung 7 (re-entry): disclosed production volume under a current customer or application.
Samsung StarPlus Energy, Kokomo, Indiana — Rung 6 (NCA EV, Status Uncertain) / Rung 5 (LFP ESS)
Samsung SDI's March 2026 release states StarPlus has been gradually converting production lines from EV (NCA) to ESS batteries since Q4 2025, with LFP mass production expected in Q4 2026, supported by a KRW 1.6 trillion LFP cathode supply agreement with L&F starting in 2027. For NCA EV cells: approximately Rung 6. StarPlus was previously producing for Stellantis, but current NCA production status is undisclosed, and the conversion language implies line repurposing is underway. For LFP ESS cells: Rung 5 at best. Equipment is being converted, but no LFP commercial production has been disclosed. Samsung SDI's Q1 2026 IR deck references expanded US ESS project orders and a "non-PFE LFP materials" supply chain but provides no StarPlus-specific production volume, utilization, named ESS customer taking delivery, or facility-level compliance evidence. Stellantis's 2025 Form 20-F (filed February 26, 2026) includes StarPlus as a JV entity but contains no 45X, PFE, MACR, or production-volume disclosure. Samsung SDI's reference to "non-PFE" sourcing describes supply-chain design intent without constituting a compliance filing. Missing for Rung 7 (LFP): disclosed LFP commercial production start. Missing for Rung 10a: any facility-level 45X credit claim or MACR calculation.
LGES Lansing, Michigan — Rung 7 (Existing ESS) / Rung 8 (Tesla-Specific, Pre-Production)
Split assessment required. LGES's Q1 2026 deck lists Lansing as "In Operation" under North American ESS capacity, covering LFP pouch and LFP prismatic products, and references revenue supported by "active response to ESS customer demand through capacity expansion in North America." This places existing operations at Rung 7, though no facility-level volume, yield, or customer-shipment data is disclosed. Separately, the DOI announcement of a $4.3 billion supply agreement between Tesla and LGES for LFP prismatic cells, with production launching in 2027 for Megapack 3, places the Tesla-specific line at an unusual position: Rung 8 evidence (named customer, public supply agreement) before production has started. The customer commitment is public and named, but the product does not yet exist. The production, yield, and compliance rungs below it remain uncleared for this specific line. Tesla's Q1 2026 Form 10-Q does not mention LG Energy, Lansing, 45X, MACR, or PFE. LGES discloses a corporate North America production incentive of KRW 189.8 billion in Q1 2026 but does not allocate it by facility. Missing for Rung 9: facility-level output rate or yield. Missing for Rung 10a: facility-level 45X credit claim or MACR calculation.
Ford BlueOval SK, Glendale, Kentucky
Audited separately in this issue.
What the Ladder Measures
None of the four demonstrated facilities has a publicly verifiable facility-level 45X credit claim, MACR calculation, or PFE compliance package as of July 10, 2026. MACR safe harbor tables remain unpublished.
LGES's corporate-level production incentive disclosure is the closest evidence, and it is not facility-allocated.
The distance between Rung 7 and Rung 12 is where procurement teams discover that "US battery manufacturing capacity" and "contractable domestic supply" describe different things. A facility can be built, equipped, commissioned, and producing cells while remaining five evidence thresholds from supply a buyer can contract against with the compliance documentation a clean vehicle credit or bankable ESS offtake requires. The ladder makes that distance visible, rung by rung, so the buyer can identify exactly which risks remain open and price them accordingly.
- MACR safe harbor tables: Treasury's deadline to publish safe-harbor tables identifying PFE-attributable cost percentages for battery components is December 31, 2026, and until they appear, every facility's Rung 10a filing carries unresolved methodology risk.
- StarPlus LFP mass production: Samsung SDI's March 2026 disclosure targets Q4 2026 for LFP ESS mass production at StarPlus, which would move the facility from Rung 5 toward Rung 7 on the ESS side if accompanied by output evidence.
- FEOC graphite exemption expiry: The clean vehicle credit FEOC exemption for graphite expires December 31, 2026, potentially regressing facilities that currently clear Rung 10b back below it if their anode supply chains trace to covered-nation sources.
- Aggregate project attrition: E2's July 9 report models 468,000 jobs and $68.2 billion in foregone investment across 216 canceled or downsized clean energy projects since January 2025, useful as macro context for how many announced facilities never reach Rung 4.