I. Macroeconomic Environment and Trade Risk Analysis

For batteries and secondary battery materials (finished products under HS 8507, including many materials, precursors, and minerals), policy, supply chain, and ESG variables have a greater impact on profitability than tariffs. Pressure to localize in North America (linked to subsidies), the EU's environmental and carbon regulations, and competition to secure key minerals are all evolving simultaneously.

Risk factors

2025-26 Outlook

Influence (1~5)

Implications

North American localization (subsidy linkage)Strengthening requirements and expanding detailed notification5Simultaneous review of North American assembly and materials lines
Core Mineral Supply ChainLithium and nickel volatility continues4Long-term offtake and multi-source procurement are essential
EU environmental and carbon regulationsIncreasing demand for product and process data4LCA/Carbon Footprint Systematization
Exchange rate/logisticsModerate volatility2Optimization of CIF/FOB terms and insurance
Geopolitics and Trade PolicySelective restrictions on minerals and materials4Indirect sourcing and FTA cumulative utilization
Ⅱ. FTA Utilization Rate and Corporate Practice Statistics

While finished batteries (HS 8507.x) frequently enjoy low or zero tariffs in major markets, practical bottlenecks remain in proving origin and key mineral sources, as well as subsidy eligibility . Some materials and precursors (e.g., 2825.20 lithium compounds, 2836.91 lithium carbonate, 3801.10 graphite) still have MFNs, significantly increasing the perceived impact of FTA application and accumulation.

division

FTA/ITA applicability (trend)

On-site difficulties

Management Points

8507 lithium-ion batteryMost low-rate/tariff-free casesProof of origin of key minerals and componentsSeparate documentation system according to North American and EU requirements
2825.20/2836.91 Lithium compoundsMFN deviations exist across countriesPrecision classification and ingredient verificationTest report and COA are updated regularly.
3801.10 Natural graphite/artificial graphiteSome tariffs and TBT applyDistinction between appearance and useHS Detailed Specification and Usage Description Consistency
7502 nickel, 7403 copper, 7601 aluminumBasic material MFN validDetermination of origin and processing processParallel cumulative and RVC scenarios
III. Matrix of Comparison of Tariffs and Non-Tariffs by Country

While the US and EU have relatively low tariff burdens on finished products (8507), restrictions on subsidy and procurement eligibility and the sourcing of key minerals pose substantial barriers. Emerging countries can differentiate themselves when utilizing FTAs ​​due to the remaining MFN.

market

Representative HS (example)

MFN tariff (scope)

When FTA is applied (trend)

Non-tariff barriers (example)

Comments

USA8507, 2825, 2836Varies by item (low rate for finished products)0% high frequencySubsidy/Procurement Eligibility/Key Minerals RegulationsKey North American Production and Material Procurement Requirements
EU8507, 3801, 76010~3% cases0% majorityBattery Regulations, REACH, and Eco-DesignRising carbon, recycling, and LCA requirements
china8507, 28255~10% of items existVaries by concession/agreementCertification and Industrial PolicySimultaneous management of price, delivery, and certification
ASEAN (Vietnam, etc.)8507, Materials~5% reportedRCEP/Bilateral FTA reductionCertification and administrative proceduresValid for cumulative use within the region

Note: Actual tariff rates and requirements may vary depending on HS subheadings, function, and ingredients. It is recommended to measure HTS/TARIC before customs clearance .

Ⅳ. ESG·CBAM Impact

EU battery regulations, REACH, and Ecodesign require product-level LCA (raw materials to recycling) data. CBAM focuses on basic materials, but can be reflected in costs through indirect links such as electricity, aluminum, and graphite . Recycling and circulation (recycled content) rates are emerging as market entry requirements.

policy

applied area

Enforcement/Strengthening

Influence (1~5)

react

EU battery regulationsBattery life cycleStep-by-step reinforcement5LCA/Carbon Footprint/Recycling Rate
REACH/CLPChemical managementConstant renewal4Registration, SDS, and Alternative Materials Roadmap
CBAM (linked)Focus on basic materials → Indirect expansion2026~3Power mix and aluminum linkage management
V. Investment and Supply Chain Transition Scenario

Localization in North America : Localization of cell and module production and some cathode and anode materials, securing eligibility for subsidies and procurement.

EU Decentralization : Building anode and precursor lines + combining recycling (urban mining) to optimally address LCA.

ASEAN Processing : Primary Processing of Precursors and Materials + RCEP Accumulation to Optimize Costs and Delivery Times

Domestic R&D Hub : Maintaining pilot projects for next-generation electrolytes, silicon anodes, and high-nickel cathodes.

Ⅵ. AI-based 3-month import/export forecast (AutoLoop integration)

Forecast_3M is calculated by combining public statistics, news and policy sentiment (α), global consensus (β), and sector sentiment (λ) . The battery sector exhibits high ΔSignal sensitivity to policy news , leading to significant short-term volatility . However, both exports and investment show a gradual improvement during periods of stable material prices .

variable

Δ(%) or exponent

analysis

ΔExport_now+2.8A simultaneous increase in finished products and materials for North America and the EU
ΔImport_now+3.6Expanding imports of precursors and minerals (line expansion)
ΔPrice_now+0.5Expanding the proportion of high-nickel and silicon cathodes
ΔSignal_now+0.032Policy, demand, and exchange rate composite signals are "positive."
ΔFTAEffect+0.35FTA/Cumulative Effect + Subsidy Eligibility Response
Forecast_3M+0.56Suggesting moderate growth within three months

Formula (summary): Forecast_3M = 0.5·ΔSignal + 0.3·ΔFTAEffect + 0.2·ΔPrice

VII. Policy Recommendations and System Improvement Roadmap

field

Suggestion

Executor

Expected effect

Core Minerals StrategyStrengthening Korea-Australia-Chile Mineral FTA and Supply Chain CooperationTrade authorities and public corporationsPrice and supply stability
Origin/AccumulationEnhanced PSR/RVC Guidelines to Meet North American and EU RequirementsKorea Customs Service and Ministry of Trade, Industry and EnergySimultaneous optimization of subsidies and tariffs
ESG·LCABattery LCA and Recycling Data StandardizationCompanies and AssociationsMeet delivery requirements and receive premium
digital tradeStandardizing Cross-Border Transfer of Design, IP, and DataMinistry of Trade, Industry and Energy·KOTRAPromoting intangible value exports
Finance and InsuranceMineral Price Hedging and ESG Trade Finance PromotionMinistry of Strategy and Finance and Policy FinanceAbsorbing volatility and promoting investment
Ⅷ. Summary of Conclusions

Subsidies, procurement eligibility, key minerals, and ESG data are more important factors in determining competitive advantage than tariff reductions .

A dual supply chain is reasonable , based on FTA accumulation and regional requirement divergence (North America and EU) .

Forecast_3M: +0.56 → Short-term improvement possible, but sensitive to policy announcements and mineral price fluctuations .