Domestic manufacturing requirements are beginning to reshape how electric vehicle (EV) systems are engineered, sourced, and validated in the United States. Policies such as Build America, Buy America (BABA) and Section 45X now sit alongside traditional performance and safety considerations, influencing everything from component design to supplier qualification.
Dave Rubin, Head of Policy at Proterra
Dave Rubin, Head of Policy at Proterra — a US-based manufacturer of commercial EV technology, including batteries and powertrain solutions — works at the intersection of engineering and policy where these pressures converge. His perspective reflects the growing need for alignment between technical decisions and evolving domestic-content expectations.
In this Q&A, Rubin explains how new sourcing rules affect component and subassembly-level engineering, how friendshoring is changing supplier qualification, and why EV platforms increasingly need to be designed with regulatory and supply-chain realities in mind.
Here’s what he has to say…
How are the Build America, Buy America domestic content requirements influencing engineering decisions at the component and subassembly level, particularly for batteries and power electronics?
The Build America, Buy America (BABA) provision was enacted as part of the Infrastructure Investment and Jobs Act (IIJA) of 2021, and implemented a sweeping new set of procurement standards for federal grants and awards. It will have lasting sourcing impacts on various sectors, including the EV, charging, battery, and clean tech industries.
For projects and funding programs that must comply with BABA’s domestic content requirements, the impacts for EV, battery, and clean tech projects are stark. Any “manufactured products” (vehicles, chargers, etc.) must be made in the US and have 55% of the total costs of components produced or manufactured domestically.
Module-level assembly, where mechanical design, cell integration, and subcomponent sourcing begin to determine whether a pack can meet domestic-content expectations.
Federal agencies can grant waivers to BABA restrictions, but these are usually limited to high cost and non-availability of parts. Only a few notable examples have emerged in the clean tech space – notably, electric school buses, port equipment, and National Electric Vehicle Infrastructure Program (NEVI)-funded EV chargers.
As manufacturers in the clean tech space begin to service grants and awards covered by BABA, these requirements will not only affect engineering decision-making, but also supply chain, sourcing, policy, and legal considerations. To meet these requirements, there’s pressure to increase component manufacturing stateside, and develop alternative domestic supply for subcomponents.
The challenge, of course, is that battery and power electronics supply chains are extremely international, and onshoring of these sectors will take time. Companies that make the investments in the short-term will be best-positioned to support BABA projects in the years ahead.
Must engineers now redesign parts or adjust specifications to ensure systems meet domestic sourcing thresholds under BABA?
Yes… but it’s not just an engineering exercise. What BABA is really forcing is “design for procurement,” which means engineering, supply chain, and policy sitting at the same table from day one.
On the battery side, it’s important to evaluate:
- What is the manufacturing footprint for the sub-components that constitute a pack?
- What content upside exists when shifting sourcing to the US without compromising safety, cost, or performance?
Over the longer-term, this could lead to working with suppliers for parts like enclosures, harnesses, busbars, BMS PCBs, and more that have, or could in the future, build a US footprint.
Should BABA change in the future, manufacturers could also develop modular designs where the same pack architecture can be built in a BABA-compliant configuration (with US content maximized) or a global configuration, to support federally funded and commercial customers.
With limited US production of critical minerals such as lithium, nickel, and graphite, what technical approaches are materials engineers taking to maintain supply stability?
The current stress test for BABA application is done at the “component” level. For battery packs, this includes modules, enclosures, and ancillary bays. For raw materials today, the lever is less about making “everything domestic now” and more about building optionality for the future, particularly given the current uncertainties in US trade and industrial policy.
However, there are other recent changes beyond BABA. The amendments to the 45X Advanced Manufacturing Production Credit and other clean tech credits in the One Big Beautiful Bill — which provide incentives for US manufacturing of cells and modules — have stricter content thresholds and prohibitions against material sourcing from Prohibited Foreign Entities (PFEs).
Given these realities, the industry is working on two main fronts:
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Chemistry choices that align with friendlier or more diversified supply chains: Certain technologies, like LFP and high-manganese cathode, have more complex supply chain considerations than traditional architectures. That’s a technical choice, but it’s made with a clear view of which materials have the most credible US and allied development pipelines — at least until such a point as newer chemistry entrants have a chance to mature and for local sourcing options to expand.
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Recycled and secondary feedstock integration: Materials engineers are increasingly treating recycled material and “black mass” as a primary feedstock, not an afterthought. By designing processes to accept a blend of primary and recycled materials, they help create a demand signal for domestic recycling and refining capacity. In practice, this one of the fastest ways to build a North American source of lithium, nickel, and graphite precursors that can satisfy not just BABA, but also other requirements like USMCA and 45X.
Although one cannot fix global mineral supply overnight, the technical decisions made today either lock us into brittle supply chains or, ideally, offer procurement multiple pathways to secure US and non-PFE supply over the next decade.
Considering 100% domestic manufacturing is not yet possible, what practical technical or sourcing actions can reduce risk from foreign dependencies?
It’s important to start by being realistic. For the medium term, some foreign dependency is unavoidable, given the intricate, complex, and nascent nature of many players in this space. The question is how to shape that dependency so it’s lower risk and more resilient.
Battery-system production in US plants now requires linking manufacturing workflows with supplier qualification, traceability, and federal content compliance.
For sourcing, this means diversifying away from single-country exposure. Examples include prioritizing suppliers in countries with strong trade relationships, clear Environmental, Social, and Governance (ESG) standards, and aligning security interests, Essentially, this is “friendshoring,” even when the program isn’t formally labeled that way.
In the battery sector, for instance, an effective approach uses a two-tiered strategy:
- Identifying opportunities to deleverage from PFEs, where tariff and geopolitical risk are highest
- Determining which components can be onshored in a cost-competitive way over the long term
Together, these steps don’t eliminate foreign dependencies, but dramatically reduce the risk that a single policy change, export restriction, or factory disruption will grind a US operation to a halt.
How does friendshoring work, and what impact does it have on qualifying allied-country suppliers and on testing, validation, and certification timelines?
Friendshoring is the idea of building supply chains across countries that share strategic interests, regulatory norms, and relatively stable trade relationships, rather than simply chasing the lowest-cost global supplier.
For batteries, that often means sourcing critical minerals and intermediate products from partners like Canada, Australia, South Korea, Japan, and EU member states. Typically, these nations are investing in their own upstream and midstream capacity and have closer alignment with US security, economic, and environmental standards.
Operationally, friendshoring presents unique benefits in risk mitigation, even if content requirements are less affected, including:
- Identification of and engagement with allied-country suppliers can help shape their capabilities toward future needs, particularly as these suppliers grow. This can also present opportunities for newer collaborations, technologies, and joint development, which leverages US foreign policy goals around advanced technology, security, etc.
- Deeper traceability in the qualification process. Engineering, compliance, and procurement can often rely on origin-verification protocols and supplier audits that are more closely aligned with US trade governance principles, alleviating compliance burdens.
- Testing and validation timelines can initially lengthen, because this means onboarding more new suppliers rather than sticking with legacy ones. However, once common standards and test plans across a network of allied suppliers are fully established, subsequent qualifications can move faster.
- Collaboration can often drive innovation, tapping into joint development funding programs and incentives, which help achieve mutual multi-lateral goals of the US and its allies abroad.
Essentially, friendshoring is about trading a bit of near-term complexity for long-term resilience and alignment with evolving US content and security policies, which is particularly important in periods of trade uncertainty.
As American EV manufacturing scales up, what new skills or collaboration models are required for engineering teams to meet performance goals and regulatory expectations?
The biggest shift is that engineering decisions must increasingly be made in the context of procurement, policy, compliance, and supply chain.
Teams must be able to translate design decisions into domestic-content outcomes, tariff exposure, and long-term sourcing resilience. Engineers need not become lawyers, but an understanding of the constraints they’re designing within are critical.
In this context, two topics come to mind:
- Design for regulation: Engineers increasingly need fluency in domestic content rules, origin requirements, and key procurement constraints. This doesn’t mean becoming policy experts, but it does mean designing products with awareness of how component choices affect BABA compliance, as well as other programs like the United States-Mexico-Canada Agreement (USMCA) and IRA tax credit eligibility.
- Design for sourcing: Similarly, as supply chains shift toward domestic and allied-country suppliers, engineers need to structure designs around what can be built competitively in the US where possible. For BABA, this means thinking through component and sub-component manufacturing design footprints, and overall cost-content structure.
What ties all this together is a shift toward building products and supply chains simultaneously. Engineering is no longer just designing components and manufacturing footprints. To ensure success, efforts must be fully aligned with the policies that support a resilient, US-anchored industrial base.
Filed Under: Batteries, Featured Contributions, Q&As