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World Electric Vehicle Journal
  • Review
  • Open Access

14 October 2025

Circular Economy and Sustainability in Lithium-Ion Battery Development in China and the USA

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HeatSync, 10840 Minette Dr., Cupertino, CA 95014, USA
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Author to whom correspondence should be addressed.
This article belongs to the Special Issue Electric Vehicle Battery Pack and Electric Motor Sizing Methods

Abstract

The surge in electric vehicles (EVs) and renewable energy has made lithium-ion batteries (LIBs) critical to the global energy transition. This review examines how LIBs contribute to a circular economy, focusing on China and the United States as key actors shaping the battery value chain. We analyze technological advancements, market growth, supply chain dynamics, ESG risks, and strategies for recycling, reuse, and next-generation chemistries. China’s approach centers on vertical integration and scale, while the U.S. emphasizes innovation, policy incentives, and diversification. Despite progress, gaps remain in closed-loop systems, ethical sourcing, and supply chain resilience. Realizing sustainable battery growth will require coordinated efforts in technology, governance, and international collaboration to align resource efficiency with long-term environmental and economic goals.

1. Introduction

The transition to a circular economy is fundamentally reshaping the global energy storage landscape. At the center of this transformation is lithium-ion (Li-ion) battery technology, which is the primary focus of this paper, valued for its superior energy density, extended life cycles, and efficiency. These batteries are now indispensable across applications ranging from consumer electronics to electric vehicles (EVs) and large-scale grid energy storage. Projections suggest that by 2030, lithium-ion batteries will also play a central role in shipping and aviation, further underscoring their strategic importance in the global energy transition [].
The historical development of EVs illustrates the close link between advances in battery technology and clean mobility. From the first electric carriages of the 19th century to the modern EV revolution led by companies such as Toyota and Tesla, battery innovation has been a consistent driver of progress [,]. Similarly, the adoption of battery energy storage systems (BESSs) has accelerated, supporting renewable integration and enhancing grid reliability, as demonstrated by projects like the Moss Landing Energy Storage Facility in California [].
Given this pivotal role, the objective of this paper is to examine how lithium-ion battery technology contributes to advancing a circular economy, with a particular emphasis on the contrasting strategies of China and the United States. It is important to emphasize that Li-ion batteries are not discussed here as one illustrative case among many energy storage technologies, but as the central subject of analysis due to their dominance in current and near-term markets. We analyze technological development, supply chain structures, market dynamics, recycling initiatives, and policy frameworks in both countries to identify opportunities, challenges, and implications for global sustainability.
China and the United States were selected for focused comparison because they represent the two dominant poles of the global LIB industry in both scale and strategy. In 2024, global LIB shipments totaled ~1545 GWh, of which China accounted for ~1215 GWh (79%), reflecting its overwhelming lead in production and supply chain control []. China also produced ~1170 GWh of LIBs (76% of global output) and refined more than 80% of lithium, cobalt, and graphite, giving it unmatched influence across the value chain [,,]. By contrast, the United States is emerging as the primary counterweight to this dominance. While U.S. production remains smaller in scale, operational capacity exceeded 200 GWh in 2024 due to IRA-driven investments and the growth of the “Battery Belt” in the Southeast []. Tesla alone produced ~9 GWh of 4680 cylindrical cells in 2024 and is completing a 10 GWh/year LFP factory in Nevada for stationary storage [,,]. These enterprise-level efforts are reinforced by federal policies, including the Inflation Reduction Act and Domestic Content Agreement rules, which incentivize domestic production, recycling, and next-generation chemistries.
Other regions—such as the European Union, Japan, and South Korea—are important players and are referenced throughout the paper. However, China and the United States together exert the greatest systemic influence on the global battery value chain. China exemplifies a vertically integrated, policy-backed model of scale, while the U.S. represents a policy- and innovation-driven pathway. This dual-pole comparison provides the clearest lens for analyzing how national strategies shape circular economy outcomes, sustainability, and supply chain resilience.
To guide the reader, the remainder of this paper is structured as follows: Section 2 reviews the global evolution of lithium-ion batteries, including technological progress, demand growth, supply chains, materials, environmental and social risks, recycling strategies, production patterns, and cost trends. Section 3 presents a comparative analysis of China and the United States, highlighting their distinct approaches in industrial leadership, policy support, enterprise strategies, and circular economy practices. Section 4 discusses the broader implications of these trajectories, drawing on quantitative comparisons and the recent literature. Section 5 summarizes the main conclusions, while Section 6 outlines future directions for research, policy, and international collaboration.

2. Global LIB Technical Evolution, Market Demand, and Supply Chains

2.1. Lithium-Ion Battery Evolution over Time

Since 2010, the transition from nickel-hydride and lead-acid to lithium-ion batteries (LIBs) has defined electromobility and energy storage []. LIBs offer high energy density (up to 750 Wh/L, 270 Wh/kg) [], long cycle life (1000–6000 cycles), and durability. Technological progress focuses on increasing energy density, reducing costs, and improving safety. Modern LIBs comprise a cathode, anode, electrolyte, and separator [].
Cathode innovations, particularly lithium nickel manganese cobalt oxide (NMC), have improved capacity and stability [,,]. Variants like NMC111, NMC622, and NMC811 reflect trends toward higher nickel and lower cobalt use [,,,], though high-nickel cathodes require enhanced coatings and electrolyte formulations for thermal stability. Lithium iron phosphate (LFP) batteries, while lower in energy density, excel in safety and cycle life, making them suitable for public transport and stationary storage [,,,]. Emerging post-LIB technologies—sodium, magnesium, aluminum, solid-state, and lithium-sulfur—promise higher energy density and improved sustainability, though commercial scalability remains a challenge []. Figure 1 shows projected cathode market shifts to Fe- and Mn-based chemistries by 2040 [].
Figure 1. Projected market share trends of cathode chemistries over time. Adapted from [].

2.2. Battery Demand

Global demand for lithium-ion batteries has grown at ~33% annually over the past three decades, accelerating to ~40% in the last ten years with EV adoption []. In 2024, shipments reached ~1545 GWh, a 28.5% increase from 2023 []. EVs overtook consumer electronics as the largest consumer in 2018 and by 2024 represented the majority of demand. Stationary storage, while smaller, is projected to surpass 200 GWh annually by 2030 [,,,]. These sectoral shifts are illustrated in Figure 2, which highlights the transition from electronics to EVs as the dominant demand segment.
Figure 2. Global battery sales by sector, adapted from [,,,].
In 2023, Asia-Pacific held 56% of global demand, followed by North America (19.4%) and Europe (16.2%) []. This distribution underscores the Asia-Pacific’s dominant position in the global market. Figure 3 shows projected growth to 2600–10,000 GWh by 2030, driven by chemistries like LFP and high-nickel variants [,,]. Meeting this demand requires robust recycling, reuse, and supply chain efficiency [,,,,,,,].
Figure 3. Annual trends in global battery demand, adapted from [].

2.3. Battery Materials Supply Chain

Lithium, nickel, and cobalt are critical for lithium-ion batteries, with supply chains spanning mining, refining, and production. China dominates refining across all three, reinforcing its global strategic position.

2.3.1. Lithium

Australia leads lithium mining (52% of global output), followed by Chile (22%), China (12%), and Argentina (7%). Key firms include Albemarle, SQM, Tianqi, and Ganfeng. China refines ~60% of global supply, with Argentina (12.5%), Australia (8.8%), and Chile (7.5%) trailing []. Lithium prices rose sharply from 2015 to 2018 with EV demand, peaking at $80,000/ton in 2022 before collapsing to ~$14,000/ton in 2023 due to oversupply and EV demand slowdown [].

2.3.2. Nickel

Indonesia produces 33% of global nickel, followed by the Philippines (12%), Russia (11%), New Caledonia (8%), and Canada (8%). Major miners include Vale, Sumitomo, Norilsk, and Tsingshan. China refines ~49% of global nickel, with Finland (17.3%) and Indonesia (11.3%) as secondary players []. Nickel prices are typically stable but spiked 70% in March 2022 due to supply concerns after Russia’s invasion of Ukraine [].

2.3.3. Cobalt

Cobalt, the most expensive LIB material, is concentrated in the DRC (69% of mining), with Russia and Australia contributing 4% each. Refining is dominated by China (78.6%), followed by Finland (8.7%) and the DRC (6.7%) []. Cobalt demand grew from ~100 kt in 2015 to 175 kt in 2021 but fell in 2023 as LFP batteries gained share []. Tesla and Ford are shifting toward cobalt-free chemistries []. Figure 4 and Figure 5 show country shares in mining/refining and price trends for lithium, nickel, and cobalt.
Figure 4. The shares of major countries in mining and refining of (a) Lithium, (b) Nickel, (c) Cobalt. Adapted from [].
Figure 5. Battery-grade (a) Lithium, (b) Nickel, and (c) Cobalt prices from 2010 to 2024. Adapted from [,,].

2.4. Environmental and Societal Risk

Cobalt poses high ESG risks due to child labor and environmental contamination in the DRC [,,,,,]. Lithium extraction raises water concerns but has lower overall ESG risks [,]. Nickel production generates significant GHGs and SO2 emissions, varying by source [,]. Addressing these impacts requires responsible sourcing, stringent regulations, and recycling initiatives [,]. Figure 6 illustrates ESG risk levels.
Figure 6. ESG risk levels for lithium, iron, nickel, and cobalt, where environmental risks include waste, water, and conservation, and social risks encompass communities, land use, and social vulnerability. The ESG number represents the risk level, with 100 indicating high risk. A lower ESG number signifies a lower risk level. Adapted from [,].

2.5. Reuse, Repurpose or Recycle Batteries

The rapid growth in lithium-ion battery usage for electric vehicles, electronics, and energy storage highlights the need for robust reuse, repurposing, and recycling strategies. These approaches are essential to advancing a circular economy by reducing waste and maximizing material value.
Reuse and repurposing extend battery lifespans by deploying used batteries in less demanding applications, such as stationary energy storage systems. However, adoption is hindered by the limited availability of suitable batteries, logistical complexities, and the need for standardized collection and evaluation protocols. Demonstration projects have shown promise but require scaling to realize their potential.
Recycling enables the recovery of critical materials like lithium, cobalt, and nickel, reducing reliance on primary raw materials and mitigating mining impacts. Challenges include extracting materials from diverse chemistries and managing collection and transportation [,]. Advanced technologies promise higher recovery rates and energy efficiency, supporting the need for significant capacity expansion.
A systems-level approach integrating reuse, repurposing, and recycling is vital. Policymakers can enact regulations and incentives, while industry stakeholders invest in technology and streamline collection processes. Raising consumer awareness and implementing deposit-return schemes can further enhance participation. Integrating these strategies reduces waste, conserves resources, and supports sustainability goals. Businesses can generate revenue, and policymakers can mitigate resource dependency, driving a transition to sustainable energy.

2.6. Battery Production

As shown in Figure 7, China, South Korea, and Japan dominate the global battery market, collectively holding 90% of the market share. China, as a global leader in lithium-ion battery production, controls over 70% of the market and nearly all stages of the battery supply chain. Chinese companies such as CATL and BYD lead the market, with CATL holding a significant 36.8% market share and BYD 15.8%. South Korean firms like LG Energy Solution and Samsung SDI also play crucial roles, with market shares of 13.6% and 4.6%, respectively. Japan’s Panasonic contributes a 6.4% share. The chart below highlights the dominance of Chinese companies and the significant presence of South Korean firms in the battery production industry.
Figure 7. Market share of leading countries in lithium-ion battery production, highlighting the share of top Chinese manufacturers. Adapted from [,].

2.7. Battery Price Trends

Battery costs have fallen by 99% over the last three decades, driven by technological advancements, economies of scale, and widespread deployment, while energy density has increased fivefold []. Between 2013 and 2023, average lithium-ion battery pack costs fell by 82%, from over $700/kWh to $139/kWh, while cell costs declined to $96/kWh; pack assembly costs remained around $43/kWh []. These declines underscore lithium-ion as one of the fastest-evolving clean energy technologies.
Prices are shaped by supply-demand dynamics, geopolitical conditions, and technological breakthroughs. Stable access to lithium resources, evolving trade policies, and advances in chemistries and extraction methods can lower costs, whereas strict environmental regulations may raise them. Innovations in sustainable mining and recycling, however, provide long-term price stability [].
Economies of scale remain pivotal, yielding ~19% cost declines and 7% energy density gains with each deployment doubling. By 2030, costs could drop to $32–$54/kWh, with densities reaching 600–800 Wh/kg (Figure 8) [,]. Policy support in the U.S. and China accelerates these trends by promoting recycling, reuse, and innovation, aligning with circular economy goals to enhance resource efficiency and supply chain resilience.
Figure 8. Battery cell demand and cost trends over time. The solid lines show historical data, while the dashed and dotted lines indicate projected estimates for future years under scenarios of fast and faster growth. Adapted from [,].

3. China-US LIB Industry Strategic Comparisons

3.1. China’s Path to Battery Manufacturing Leadership

China has secured a dominant position in global lithium-ion battery manufacturing through a combination of resource control, industrial policy, technological innovation, and strong domestic demand. In 2024, Chinese firms supplied more than 75% of global LIB output, with CATL holding 37.9% and BYD 17.2% of the global EV battery market []. Together, they accounted for over half of worldwide installations, underscoring the scale of China’s leadership.
A central pillar of this dominance is control over raw materials. Between 2018 and 2021, Chinese companies invested over $4.3 billion in overseas lithium mining [], while also securing stakes in cobalt, nickel, and manganese projects. Today, China refines over 80% of global lithium, cobalt, and graphite, ensuring supply stability and cost efficiency, though also creating vulnerabilities to geopolitical tensions and resource nationalism.
China’s rise has been reinforced by policy and production advantages. Historically lower labor and energy costs, coupled with lenient environmental regulations, allowed rapid expansion, though ecological concerns have since prompted stricter domestic standards. Incentives under programs such as Made in China 2025 [,] propelled firms like CATL, which began in Hong Kong in 1999 and relocated to mainland China in 2008 to capture subsidies and market access. By 2024, CATL had grown into the global market leader, supplying automakers worldwide.
Technological integration and innovation have further accelerated growth. Chinese firms leveraged licensed foreign technologies to upgrade processes, while the expiration of LFP patents outside China in 2022 eliminated royalty fees, giving domestic firms a decisive cost advantage. As a result, China’s LFP production rose by over 50% year-on-year in 2023 [], consolidating leadership in safe, low-cost chemistries.
Domestic demand has been equally decisive. With EV sales surpassing 9.4 million units in 2023, representing more than 60% of global EV sales [], China provided its manufacturers with unparalleled scale, enabling rapid cost reductions and continuous innovation cycles. Large-scale deployment of renewable energy storage systems further reinforced this demand base [].
China’s battery sector also illustrates circular economy principles. Firms are scaling recycling and repurposing infrastructure to reclaim critical materials, reduce resource dependency, and mitigate environmental impacts. Advanced recycling processes are being deployed alongside expanding second-life applications, particularly in stationary storage.
Finally, Chinese companies are pursuing global expansion to diversify markets and mitigate trade barriers. CATL and BYD have established factories in Europe and Asia to localize production for major automakers such as Tesla and Toyota []. These facilities not only strengthen supply chain resilience but also embed Chinese firms into international EV ecosystems.
Overall, China’s battery leadership rests on scale, vertical integration, supportive policy, technological adoption, and robust domestic demand. While rapid growth has raised environmental challenges, the country’s integrated model demonstrates how industrial policy and circular economy strategies can be combined at scale, offering lessons for other nations seeking to develop sustainable and resilient battery supply chains.

3.2. Advancing Domestic Battery Independence in the USA

The United States has adopted a multifaceted approach to enhance domestic battery manufacturing and reduce reliance on imports, particularly from China. This strategy aligns with circular economy principles by emphasizing resource efficiency, sustainability, and local value chain development.
To strengthen domestic production, the U.S. government has introduced tariffs on imported lithium-ion batteries and components, raising EV battery import duties from 7.5% to 25% by 2024 []. In parallel, the Department of Energy’s Loan Programs Office (LPO) has provided more than $10 billion in low-interest loans since 2021 [], while states such as Georgia, South Carolina, and Michigan have offered substantial subsidies, helping attract nearly $100 billion in investment across ~30 factories and creating the emerging “Battery Belt.” The Inflation Reduction Act (IRA) reinforces these trends with a 30% investment tax credit for energy storage [], $35/kWh credits for domestic cell production [,], and new Domestic Content Agreement (DCA) rules requiring U.S. or allied sourcing for tax eligibility [] (see Appendix A for a summary of the 2024 U.S. DCA guidance).
In parallel, U.S. battery costs have declined significantly. In 2024, the average lithium-ion pack cost fell to $139/kWh, with cell costs at $96/kWh and pack assembly adding ~$43/kWh [,]. While costs in the U.S. remain slightly higher than in China, IRA incentives and expanding domestic production are narrowing this gap, improving competitiveness.
At the enterprise level, Tesla represents the most significant U.S. case study. In September 2024, Tesla announced production of its 100 millionth 4680 cylindrical cell (~9 GWh cumulative output), now deployed in the Cybertruck and other programs []. Tesla is also constructing its first lithium iron phosphate (LFP) facility in Sparks, Nevada, with ~10 GWh/year capacity, primarily targeting stationary storage (Megapack, Powerwall), and nearing completion as of mid-2025 [,]. These projects illustrate Tesla’s dual strategy of scaling high-performance cylindrical cells and diversifying into cobalt-free chemistries to reduce cost and supply-chain risk.
Complementing Tesla’s efforts, the U.S. has partnered with South Korean battery firms to accelerate cell manufacturing []. While cell manufacturing can scale quickly, securing raw materials remains the binding challenge. The U.S. is investing across the entire battery value chain, beginning with domestic lithium resources; however, environmental constraints have limited U.S. lithium production to roughly ~1% of global supply. To mitigate upstream risk and globalize competition, initiatives also include establishing allied manufacturing footprints in Africa, underscoring the broader economic-technological rivalry with China.
Recycling and repurposing are central to the circular-economy strategy. The DOE has allocated $192 million to expand lithium, cobalt, and nickel recovery infrastructure []. By reclaiming critical materials, recycling reduces reliance on primary mining and enhances supply security. Battery repurposing is another key component: used EV packs are increasingly redeployed into stationary applications, extending lifecycle value and improving grid reliability []. BloombergNEF projects ~95 GWh of used EV packs by 2025, with ~26 GWh potentially redeployed in stationary storage [].
Through this combination of enterprise investment, policy incentives, allied partnerships, and next-generation research (including solid-state and sodium-ion programs), the U.S. is working to close the gap with China. While smaller in scale, Tesla’s 4680 and Nevada LFP initiatives—coupled with IRA/DCA incentives and strengthened regional supply chains—exemplify how the U.S. seeks to advance domestic independence and circular-economy outcomes. A direct comparison of leading enterprises in China and the U.S. is presented in Table 1, highlighting the disparity in output and strategies. Taken together, these measures address dependency risks and support long-term resource security and ecological resilience while fostering a competitive domestic battery industry.
Table 1. Leading Battery Enterprises: China vs. United States (2024). Note: CATL and BYD outputs are calculated by applying their 2024 market shares (37.9% and 17.2%, respectively) to the estimated global LIB demand of ~1545 GWh [,].

4. Discussion

The comparative trajectories of China and the United States in lithium-ion battery development illustrate two distinct pathways toward advancing a circular economy. China’s approach is characterized by scale, vertical integration, and policy-backed industrial dominance. By consolidating control over raw materials, refining capacity, and cell manufacturing, China has reduced costs and accelerated deployment. In 2024, Chinese firms accounted for over 75% of global LIB output (~1155 GWh), with CATL and BYD together supplying ~852 GWh (55% of global EV battery installations) [,]. However, this concentration also introduces systemic vulnerabilities: global markets remain exposed to disruptions from geopolitical tensions, resource nationalism, or environmental backlash against intensive extraction and refining practices.
The United States, in contrast, is pursuing a strategy that emphasizes innovation, diversification, and resilience. Policy frameworks such as the Inflation Reduction Act (IRA) incentivize domestic manufacturing, recycling infrastructure, and next-generation chemistries. While U.S. domestic production remained below 200 GWh capacity in 2024, Tesla’s Nevada LFP factory (~10 GWh) and 4680 output (~9 GWh cumulative) represent enterprise-level steps toward closing the gap [,,]. Cost competitiveness is also shifting: whereas average LIB pack costs in China fell below $130/kWh in 2024, U.S. packs averaged $139/kWh, with IRA credits narrowing this difference [,]. This highlights that sustainable competitiveness may come less from matching scale and more from advancing alternative chemistries and localized cost reductions.
Several broader themes emerge from this comparison. First, recycling and reverse logistics remain underdeveloped relative to the projected demand for batteries. In 2024, China recycled an estimated 280,000 tons of end-of-life batteries, while the U.S. processed under 40,000 tons, underscoring the disparity in closed-loop capacity []. Without robust recycling systems, the growth of EVs and stationary storage risks amplifying environmental burdens rather than alleviating them. Similarly, while BNEF forecasts ~95 GWh of used EV packs globally by 2025, only ~26 GWh are expected to be repurposed in stationary storage [], showing the uncertainty of second-life applications.
Second, both supply chains are shaped by ESG concerns. Cobalt mining in the DRC, responsible for ~69% of global supply, continues to raise acute human rights issues [,,,,,]. China’s refining dominance relies heavily on coal-fired electricity, creating externalities in carbon and SO2 emissions, while U.S. domestic mining projects face opposition over land and water use [,]. Peer studies emphasize that sustainability in the battery sector requires governance frameworks integrating transparency, traceability, and equitable resource management [,].
Finally, the global implications of U.S. and Chinese strategies extend beyond their borders. As demand grows to an estimated 2600–10,000 GWh by 2030 [,,,,,,], smaller economies and allied regions (e.g., EU, Japan, South Korea) will be shaped by how these dominant actors structure trade, technology licensing, and recycling partnerships. Analysts warn that without deliberate international coordination, competition may entrench fragmented supply chains and limit equitable access to sustainable storage technologies [,].
Taken together, the evidence underscores that circular economy goals in the battery sector cannot be realized through technological innovation or industrial policy alone. What is required is systemic alignment of recycling, responsible sourcing, second-life applications, and international collaboration to ensure that the rapid expansion of lithium-ion batteries delivers both environmental benefits and long-term resilience.

5. Conclusions

This review underscores the pivotal role of lithium-ion batteries in advancing a circular economy, but it also highlights the divergent strategies of China and the United States in shaping the future of global energy storage. China has achieved scale and dominance through vertical integration, cost efficiencies, and extensive control over raw material refining. The United States, while less competitive in conventional lithium-ion manufacturing, is positioning itself through policy-driven incentives, recycling initiatives, and investment in next-generation chemistries.
Three critical conclusions emerge from this analysis. First, achieving circularity requires more than technical recycling capabilities: resilient supply chains and standardized reverse logistics systems must be integrated to close material loops effectively. Second, geopolitical dependencies and market concentration present systemic risks, making diversification of raw material sources and international collaboration essential. Third, the most promising path for the United States may not lie in directly matching China’s scale but rather in leapfrogging toward next-generation systems—such as solid-state and lithium-metal batteries—supported by robust R&D and policy frameworks [].
Ultimately, sustainable growth in the battery sector depends on aligning technological innovation with circular economy principles. Policymakers and industry leaders in both countries must prioritize integrated strategies that combine responsible sourcing, second-life applications, and closed-loop recycling. Such approaches will not only enhance environmental sustainability but also strengthen resilience and long-term competitiveness in the global energy transition.

6. Future Directions

Looking ahead, advancing a truly circular battery economy will require coordinated progress in technology, policy, and governance. On the technological front, priority should be given to scaling next-generation chemistries that reduce dependence on cobalt, nickel, and other high-risk materials. Parallel investments in recycling technologies, particularly hydrometallurgical and direct recycling processes, are essential to increase recovery yields and reduce environmental burdens. Expanding second-life applications for EV batteries in grid storage also warrants further research into safety protocols, standardization, and business models to ensure these solutions are economically viable at scale.
At the policy and governance levels, international cooperation will be critical. Establishing global standards for material recovery, supply chain transparency, and ESG compliance can help reduce risks associated with resource concentration and human rights abuses. Cross-border collaboration—whether through bilateral agreements or multilateral platforms—will enable knowledge-sharing, technology transfer, and more equitable access to sustainable energy storage. Finally, researchers should focus on integrating life-cycle assessments into battery innovation pipelines, ensuring that new chemistries and manufacturing practices are evaluated not only on performance and cost, but also on long-term sustainability.

Funding

This research received no external funding.

Data Availability Statement

No new data were created or analyzed in this study. Data sharing is not applicable to this article.

Conflicts of Interest

Authors Daniel Yousefi and Azita Soleymani were employed by the company HeatSync. The authors declare that the research was conducted in the absence of any commercial or financial relationships that could be construed as a potential conflict of interest.

Appendix A

Notice 2024-41 provides updated guidance on the IRA’s domestic content bonus credit, requiring a percentage of materials and components to be sourced domestically or from allied nations for a 10% tax credit. The table below outlines the new requirements for incorporating domestic steel, iron, and other manufactured products in energy projects.
Table A1. Battery Electric Storage System (BESS) DCA requirement, adopted from [].
Table A1. Battery Electric Storage System (BESS) DCA requirement, adopted from [].
APCMPCGrid-Scale BESSDistributed BESS
Battery PackCells38.018.1
Packaging3.330.1
Thermal Management System4.99.0
Battery Management System5.29.0
Production21.127.3
InverterPrinted Circuit Board Assemblies1.73.8
Electrical Part 90.60.4
Climate Control0.4-
Enclosure0.60.4
Production1.91.9
Battery Container/HousingBattery Racks and Metal Enclosure15.8-
Production6.5-
Steel or Iron rebar in foundation-Steel/Iron Product-
Total-100100

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