FEOC Compliance Checklist for EV Batteries
A procurement-ready audit for Section 30D Clean Vehicle Credit eligibility. Work through each block for every battery cell, module, and applicable critical mineral in your supply chain.
1. Identify FEOC Jurisdictions
- Confirm you are screening against the four covered nations: China (PRC), Russia, North Korea, and Iran.
- Flag suppliers whose ultimate parent, board, or 25%+ equity holder is domiciled in a covered nation.
- Document subsidiaries operating in covered nations even if headquartered elsewhere.
2. Trace Battery Components
- Map every cathode, anode, separator, and electrolyte supplier back to raw-material producer.
- For each cell, list the country of extraction and the country of processing separately.
- Retain purchase orders, invoices, and mill certificates for a minimum of 4 years post-sale.
3. Audit the Big Three Minerals
- Lithium: verify brine/spodumene source and refining facility; DRC-processed material sourced through a Chinese refiner is FEOC-tainted.
- Cobalt: trace from mine-of-origin (often DRC) through refiner; Chinese refining is disqualifying even with allied mining.
- Graphite (natural and synthetic): confirm anode-grade processor location; China currently controls ~90% of processing — plan a two-year exemption exit ramp.
4. Corporate-Structure Review
- Request a signed FEOC attestation from each Tier-1 and Tier-2 supplier annually.
- Screen board-of-director rosters and 25%+ shareholders against Treasury guidance.
- Document any licensing or technology-transfer agreements with covered entities — these can taint an otherwise clean supplier.
5. Documentation & Reporting
- Maintain a per-vehicle bill of materials that ties each battery to compliant suppliers.
- Prepare an annual FEOC compliance report signed by an executive officer.
- Establish an escalation path so procurement can flag suspected FEOC exposure within 30 days.