Anode Tariff Reversal
On March 12, 2026, the ITC voted 2-1 that Chinese AAM imports are "not materially retarding the establishment" of a domestic industry. Commissioner Kearns dissented. Commerce had already found combined AD/CVD margins around 160% (final CVD 66.82–66.86%, AD 93.5%, China-wide 102.72%). Both agencies must concur for orders to issue. They did not. Cash deposits collected during the investigation will be refunded.
The petitioner coalition (Anovion, Syrah Technologies, NOVONIX, Epsilon Advanced Materials, SKI US) proved the subsidies and proved the dumping. The ITC applied the "material retardation" standard reserved for nascent industries and concluded the domestic sector was too embryonic to demonstrate harm. A structural catch-22 now sits in the record: trade protection requires an established industry, but reaching scale without protection is precisely what these producers cannot do. SK On's termination of its procurement agreement with Westwater Resources on March 31, 2026, illustrates the commercial environment they face without it.
AESC US Footprint — Stated vs. Observed Audit
AESC has three US facilities. Florence is twelve months into a construction "pause" with no disclosed financing and identical company language at every update. Bowling Green received $105M in state forgivable loans and has produced no independently verifiable evidence of progress since structural topping-out in September 2023; its first job target doesn't trigger until 2029. Smyrna is producing LFP cells, but under a newly formed entity whose retained AESC licensing structure has not been tested against FEOC rules. Three facilities, three distinct modes of divergence. The ledger tracks each.
AESC US Footprint — Stated vs. Observed Audit
AESC has three US facilities. Florence is twelve months into a construction "pause" with no disclosed financing and identical company language at every update. Bowling Green received $105M in state forgivable loans and has produced no independently verifiable evidence of progress since structural topping-out in September 2023; its first job target doesn't trigger until 2029. Smyrna is producing LFP cells, but under a newly formed entity whose retained AESC licensing structure has not been tested against FEOC rules. Three facilities, three distinct modes of divergence. The ledger tracks each.
Four JV Dissolutions. 50 GWh Stated. 16.5 GWh Verified.
Four OEM–Korean battery manufacturing joint ventures have unwound within twelve months. Ford, GM, and Stellantis each exited battery cell ownership. LGES absorbed most of the assets, targeting more than 50 GWh of North American ESS capacity by year-end 2026. Verified production traceable to a named facility with confirmed output: 16.5 GWh, at Holland, Michigan. The entity responsible for closing that 33.5+ GWh gap posted a Q1 2026 operating loss of KRW 207.8 billion. Every other facility in the cohort is at some stage of conversion, from shuttered-with-announcement to ramping-without-confirmed-output. That gap between stated capacity and verified production is the supply concentration risk.
Four JV Dissolutions. 50 GWh Stated. 16.5 GWh Verified.
Four OEM–Korean battery manufacturing joint ventures have unwound within twelve months. Ford, GM, and Stellantis each exited battery cell ownership. LGES absorbed most of the assets, targeting more than 50 GWh of North American ESS capacity by year-end 2026. Verified production traceable to a named facility with confirmed output: 16.5 GWh, at Holland, Michigan. The entity responsible for closing that 33.5+ GWh gap posted a Q1 2026 operating loss of KRW 207.8 billion. Every other facility in the cohort is at some stage of conversion, from shuttered-with-announcement to ramping-without-confirmed-output. That gap between stated capacity and verified production is the supply concentration risk.
2026 US Battery Policy Reference — Operative, Gapped, Pending, Unknowable
Four tiers of US battery policy as of May 2026: operative and enforceable, issued but gapped, pending with known deadlines, and structurally unknowable from public sources. The FEOC graphite exemption expires December 31 with no extension proposed or signaled. The domestic anode capacity the policy architecture assumed would exist by then largely does not. Every entry cites its source document, names its effective date, and marks inferred status as inferred. Open this before modeling §45X eligibility, calculating a tariff stack, or qualifying a sourcing route for 2027 vehicle programs.
2026 US Battery Policy Reference — Operative, Gapped, Pending, Unknowable
Four tiers of US battery policy as of May 2026: operative and enforceable, issued but gapped, pending with known deadlines, and structurally unknowable from public sources. The FEOC graphite exemption expires December 31 with no extension proposed or signaled. The domestic anode capacity the policy architecture assumed would exist by then largely does not. Every entry cites its source document, names its effective date, and marks inferred status as inferred. Open this before modeling §45X eligibility, calculating a tariff stack, or qualifying a sourcing route for 2027 vehicle programs.
Reference Stack
