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His solution was a facility that could provide a continuous, nonstop process from raw material to finished product. That facility was the Rouge River plant. It had one goal: to create the components and materials his production lines needed, removing his dependencies on outside suppliers. To supply it, Ford Motor Company eventually bought iron mines, timberlands, and millions of acres of the Amazon jungle to grow its own rubber trees. Combining raw material control with a unified manufacturing infrastructure gave Ford absolute security of supply.

This end-to-end manufacturing framework was not to last, however, as the Great Depression exposed the downside risk of owning every stage of production. When demand collapsed, those physical assets turned into unsustainable overhead, still, this model stayed mostly in place until Henry Ford’s death in 1947. After that, Ford moved steadily toward decentralization, relying on a growing base of outside suppliers.

The Ford Motor Company was not alone; by mid-century vertical integration was on the way out across most Western industrial sectors. Offshoring allowed companies to shift the burdens of labor disputes, union pressures, and environmental compliance onto foreign suppliers while cutting material costs. But the fallout from this transition went far beyond just the loss of upstream and midstream supply chains. Decades of outsourcing stripped the United States of its ability to maintain end-to-end production, leaving it beholden to foreign powers not just for raw inputs, but for the fundamental capacity to refine and engineer them.

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After reading that article, I decided Abe and I needed to take a walk for several reasons. There is a storm rolling in, and it would also give me a chance to mull over what I had read.

Turns out I do some of my best thinking while watching Abe seemingly break the laws of physics when he props himself up on three legs to claim every bush and clump of grass he comes across as his territory. And what I needed to work through was this article was repeating a narrative that has been showing up more and more, and not just in niche trade publications.

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So I went and looked at the circulars and the trash bin (StockTwits), and I saw there are still people scratching their heads on why, after the news dropped that American Battery Technology Company ABAT got the waiver for black mass, the price tanked.

First, and this is a nitpick, but as I told someone who wanted to start covering the more technical aspects of the critical minerals market, terminology is king. Once you learn the proper lexicon, most everything else gets a lot easier.

Anyways, what ABAT was granted from the Department of Commerce was an interim license with an export allowance of $100 million in black mass. But that still seems like good news, so the question stands:

Why did the price tank on good news?

One of the reasons the share price tanked was that it spiked right after the news dropped, and that spike happened during pre-market. In my opinion, that spike was due to how all these sites now use AI to scrape and copy articles, and the AIs decided to play the old game of telephone and created some rather odd headlines. There were several versions, but this one from the Manila Times is a good example:

American Battery Technology Company Receives Approval for Sale of $100 Million of Exported Recycled Black Mass Critical Minerals with License from U.S. Department of Commerce

Those types of headlines caused the algos to go crazy for a bit. But because it was PM, the liquidity at the higher prices got thin, and that is when the shorts stepped in.

I am sure there was some profit taking, but most of the retrace was shorts working it back down. If someone had done a screen recording, they could have used it as a teaching model in a class called How to Short Momentum Stocks 101.

But why were the shorts so successful?

Investors have been waiting for the Golden September, which didn’t happen, and the Silver October, which could still happen. Those two months are the traditional months when sales surge and there is peak customer demand in China. For lithium, those are the months when the companies in the supply chain as well as the actual cell manufacturers restock ahead of Q4. This bump after what is always a slow summer has historically caused a rally in both the physical and equity markets.

The problem is due to the price of lithium going over 20K and hanging out there most of the year, many producers have been content to just buy what they need and wait for the spot prices to start dipping, which they are now doing, that is why we may still see a Silver October.

The upside, I guess, can be that we did not get a boom-bust cycle and so far just a reasonable pullback due to what looks like current capacity still outpacing demand. What to watch will be once we roll into 2027 and before the Chinese New Year. That is when we should start to see some actual procurement numbers for BESS projects, not just estimates that are being used to hold a spot in an interconnection queue.

My opinion on what that will look like is, the numbers we have been seeing in 2026 will end up being overinflated, but at the same time there really won’t be enough room to put a negative spin on those numbers due to the actual growth of ESS. So while the year-over-year growth represented in % is rather misleading without the underlying GWh, what will be listed will still be impressive.

But back to ABAT, and the short of it (see what I did there) is that those are just a few reasons why ABAT didn’t hold its gains on good news. Ironically, it mostly doesn’t really have anything to do with how the company is run, which from what I have been told is pretty damn efficient if a tad bit unorthodox due to how they compartmentalize even intra-company communications.

But rather, and this is not just lithium centric, the entire critical materials sector is weak right now even if we are seeing amazing news all the time. The problem is, and this is a word that got one retail investor’s jimmies all ruffled this week, the news is almost always the potential of something happening: an investment in a project, a pilot plant coming online, a second salsa option at the taco cart.

Very rarely, and mostly it’s just the majors that fall into this category, but rarely is it news about something happening that will immediately affect a company’s margins in a positive manner, and that is why for many the price drop after good news with ABAT was so infuriating, this was a positive that directly affected their margins.

Many know my opinion on the company, and for me the only real problem with the company, ever since they got rid of their toxic debt, is their lack of communication, and to be specific here, what I am talking about is not the send it to the moon PRs that retail is always asking for.

Rather, what I am talking about, and I know if ABAT wanted to they could do this, is to publish more frequent operational updates, updates that would allow investors to learn not only of the achievements ABAT has accomplished but also the challenges they are facing, which at times are more important than the accomplishments.

But since they use a strict milestone-driven communication strategy and only release news at or when 100% completion is all but guaranteed, and I have explained why they do this and it goes back to them missing so many deadlines, 4 of them for revenue alone. But it is this lack of progress updates that causes retail to just assume that there is nothing going on and that the shares the C-suite were awarded were inordinate and possibly negligent overcompensation for adding a second salsa option to the taco cart.

And the company is fully responsible for this kind of retail sentiment, even if the narrative fueling it is not true, but once again it is what we have come to expect from them.

So, what’s next?

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The National Assembly’s Committee on Science, Technology and Environment has released a draft law that would amend current laws and regulations. This is not the first time the Vietnamese government has used amendments to streamline the updating of its countries regulations when it comes to the handling and recycling of waste and products over the last couple of years.

I read a few of them, and upon what I have read, they have created a very extensive blueprint to build out an entire recycling infrastructure in the country from products to waste. Included in the current draft of amendments are changes to extended producer responsibilities (EPR) that put in place a recycling quota for lithium-ion manufacturers and those who import them for domestic sale.

Right now, the laws for EPR do not require a company to recycle any cells. With the new changes, they will have to recycle an 8% weight quota starting in 2029, and by 2031 the rate will be 15%. Many companies in the country have publicly stated that recycling volumes of this level are impossible for them due to the lack of feedstock, but there is a clause that allows them to keep carrying over the shortfall for 5 years.

There is, however, another problem when it comes to companies meeting this level of recycling throughput that the government is looking to mandate, and really it has to do with the lack of domestic processing and not the lack of feedstock. The proposed law includes a clause to allow for the export of the feedstock out of the country for recycling.

But by going down this path, it increases the costs associated with transport, which is one of the highest expenses when it comes to lithium-ion recycling. A draft study by SafeLoop, a European Union-funded research consortium, titled Cost-Performance Assessment and Circular Business Models evaluated several models for profitability in the EU for lithium-ion recycling and found that transport was indeed one of the key contributors to the overall costs of lithium-ion recycling.

To illustrate, the interim analysis has shown that the transportation of waste batteries to a recycling plant leads to significant logistical costs. This is because the batteries are classified as dangerous goods and, on average, are 16 times more expensive to transport than non-dangerous cargo

That is why I am sure R3 Lithium was in country having meetings with the government, and they are most likely the first of several other recycling/refinement companies that will be meeting with representatives of the Vietnamese government.

As for the rest of the changes they have done over the last few years, there was one item that was amended into their laws on environmental protection that caught my eye:

Recycled materials meeting environmental protection requirements prescribed by the Government used as production raw materials, fuels, and materials are not required to be managed per waste regulations.

Under the laws of many countries and even under international treaties, not only are end-of-life batteries considered hazardous waste, but even black mass, the intermediate product created from the mechanical stage, is classified as hazardous waste. Many countries, including the United States, are working to implement language just like what Vietnam has already added to their laws governing that waste.

For the United States, if the BRACE Act gets signed into law, it has already passed the House, it would allow lithium-ion recyclers to treat end-of-life and scrap as the valuable strategic asset it is, instead of being forced to treat it as waste under a framework built for disposal rather than recycling.

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Accurec hopes its new facility can help reduce that dependence. While the company does not claim its technology can solve Europe’s raw materials challenges on its own, it sees domestic battery recycling as an important step towards diversifying supply and keeping valuable materials within Europe rather than exporting them.

That is from a Euronews article about them and is something you do not normally see from lithium-ion recyclers. While it has become more prevalent for those, like Accurec, who have reached at least some level of commercial scale to acknowledge where they fit into the larger picture, most of the ones who are still at pre-commercial scale will instead go for the lithium-ion recycling is the way to eliminate the environmentally damaging mining and create a true green closed-loop economy.

All you need is recycling…

When I see that kind of propaganda, it is usually enough cause to ignore the company pushing that narrative. Lithium-ion recycling, or if you prefer to use the terms reclamation and refinement, is a loss prevention platform and a mechanism for maintaining material within what is called a regenerative industrial model where external inputs are supplemented by internal recovery and reuse.

S&P Global did an article the other day talking about the snapback on the price of lithium carbonate and how in August production was down 2.5% with 96,000 metric tons. What China produced in one month is over 9x what the United States produces in an entire year.

Recycling is the first step in building a domestic battery materials supply chain, and without it, the industry is bleeding material before it can even get fully started. But it will take primary sources to fill and build out the entire supply chain. And that will be the norm until the material already in the system hits a critical mass and is sufficient to meet the demand of manufacturers at such a volume that external inputs are then used as supplemental inputs; until then, recycling is a loss prevention platform.

The companies to watch are the ones who understand that synergy.

Another reason I really Accurec is for their platform, they have created a K.I.S.S. process for recycling lithium-ion, and the way they pre-treat the cells to make them open up without external physical force is a prime example of this.

In a first process step, the process chamber is evacuated while simultaneously heating the energy storage device to a first temperature level to such an extent that the electrolytes evaporate and, as a result of the resulting vapor pressure, the energy stores are opened.

They cook the cells until they pop open, that works so well that we can see a version of that process in several other platforms.

After the cells are opened up, they collect and then treat/scrub any of the harmful gases that are created when a lithium-ion cell is exposed to high heat, which are the exact same gases used to open the cells. Those gases are created from the decomposition of the binders and electrolyte, and this is one of the reasons why companies thermally pre-treat cells: it’s easier to recover a material when its no longer glued to a metallic foil.

As for lithium, they are doing an early-stage lithium recovery using roasting and carbonation, which can result in some of the highest lithium recovery out there when compared to traditional leaching, but by using carbothermic reduction and basic water leaching, most ESLR systems like this can obtain over 90% recovery of lithium.

Due to how lithium is the mobile ion in the cell, it can be one of the hardest materials to recover because it gets into everything and hides, forcing recyclers to hunt for it and try to pry it out.

The most important part of this article however is at the bottom where they talk about how Asian countries like Korea are willing to pay a higher premium for black mass because they are able to absorb that premium further downstream because they have the cell manufacturing infrastructure.

That problem is behind some of the reasons the Department of Commerce’s BIS black mass export rule was created with the requirement that 100% of the black mass be for use in domestic production. In the EU, since Korea is an OECD country, black mass producers can export black mass to them with very little regulatory obstruction. Requirements found in such things as the Basel Convention, even with black mass being categorized as hazardous waste, can be met, causing the critical materials in that black mass to be lost to the EU.

By including only exceptions to avoid harm to a company, temporary export for refinement, and the possibility that by restricting the export the rule inadvertently causes less critical minerals to be available in the US, the rule closes that gap that is found in the current set of EU rules.

This is also why I see US-based companies like R3 Lithium and American Battery Technology Company (ABAT) being more important in the short to midterm due to the shift from ternary chemistries in the US that would have been the main demand due to their use in EVs to lithium iron phosphate.

Both those platforms employ an ESLR component, and while they do end up with a lithium-depleted black mass that has to be dealt with, their platforms do extract the lithium without needing a full hydrometallurgical stage, creating less of a chance of that lithium being lost and making it available to domestic manufacturers without the entire periodic table of battery metals also being extracted.

There is also another company, and why them receiving a DOE grant makes a lot of sense: Nth Cycle. While their platform does create another intermediate, mixed hydroxide precipitate (MHP), it does allow for the creation of a lithium precursor without fully committing to battery grade for the rest of the metals.

On a technical note, while ABAT is targeting a hydroxide instead of a carbonate, adding a carbonation reactor to the platform or a simpler precipitation method off their system 4 may be financially viable because it would allow them to tap into the growing demand for lithium carbonate due to ESS. If I remember right, some lithium carbonate production equipment was part of the insolvency sale of Lithion Technologies.

Before anyone goes, “Wait a minute, we need all of the materials in black mass” and you are right that the United States needs platforms that can extract and refine all of the battery materials from black mass, however, for now, if we can get a jump on the lithium portion, these companies can get the United States a bit further down the road when it comes to creating a domestic battery materials supply chain.

I also think this rule will make direct recycling a more attractive and increase funding for the tech and the companies behind it. Instead of a platform where the cathode material is cooked and/or leached in order to create black mass or a battery-grade material, is is instead cleaned and separated then regenerated to produce one of the true supply chain bottlenecks in the United States: cathode active material (CAM).

In the context of manufacturing scrap, which is pretty homogenous and a prime candidate for this technology, direct recycling recovers the material and produces new CAM in one platform.

That is one of the reasons why I am keeping a close eye on Princeton NuEnergy; another is I will be able to use a chocolate-covered cherry analogy when describing their regeneration process. But it is because of them and a few others that if I had to pick a state to relocate to in the battery belt it would be Georgia.

Upcoming articles:

I am working on two things, well three really, but the third is kind of dependent on correspondence.

First, I am almost done with the company research for the DOE grants that will be used to shepherd some technologies from bench to prototype or prototype to pre-commercial scale.

These technologies will be able to take waste streams, whether industrial or mining; in fact, one eliminates a waste stream while extracting the primary metal. But these new technologies plan to take waste streams, reprocess them, and extract the critical materials that can be found in them.

I have also added the content needed to understand where the United States stands when it comes to recovering materials from these waste streams. The main problem is almost everything regulation-wise that is in place now and has sufficient legal precedent is focused on primary sources, not secondary.

This regulatory gap is requiring new definitions of what a deposit is and new legislation to allow companies to process these waste streams and be profitable at the same time.

Second, I am still working on how automation and AI are changing the way lithium-ion is recycled, which is why I was reading about how companies are employing video game engines to help them create disassembly sequences for a traction battery when a digital twin is not available.

Another interesting aspect involves exploring a system that allows a platform to make educated estimates based on multiple inputs to find the most efficient way to dismantle a traction battery. This process relies on metaheuristic algorithms that use swarm intelligence; without a twin, trying to hard-code every possible sequence is just too costly and time-consuming.

And what is the third?

Actually, there are a couple, and once again they are dependent on correspondence. I have reached out to a few companies to see if we can get more details about what they plan to produce from secondary sources and how they plan to do it. If you are interested in doing an interview or just having a conversation, send me an email.

Finally, September is almost over, and the bulk of it for me has been relegated to doing research. In fact, I went out into the wilds just to get away from everything to focus entirely on research.

October I will finally have the data to provide the context needed to get out some very informative and relevant articles that look at where the industry is and how the bills and regulations being worked on this year will affect these companies.

If you found this article valuable, consider becoming a subscriber. The Critical Materials Bulletin is supported by readers, and for $5 a month or $55 a year you can help fund research that produces clear, no nonsense reporting that informs and advances the discussion on critical materials and battery metals.

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Alternatively, if do not want to commit to a subscription, you can instead buy Abe a treat or two. And in doing so you can help support my goal of taking the Critical Materials Bulletin on the road, to visit these facilities as they launch, and to continue my conversations with these companies in person.

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Abe a Treat

DISCLAIMER: This article should not be construed as an offering of investment advice, nor should any statements (by the author or by other persons and/or entities that the author has included) in this article be taken as investment advice or recommendations of any investment strategy. The information in this article is for educational purposes only. The author did not receive compensation, from any of the companies and or persons mentioned to be included in the article.

First, on the earnings call, Ryan brought up that they were debt-free twice; he only repeats something if he really wants to drive home a point. If you know anything about the senior secured notes and a lawsuit that was using that debt as grounds that the company was a grifter, you would know that for Ryan it is a major accomplishment to wipe that debt off the books.

But I think it is more than that, and I have a feeling we are going to see them release the framework for some debt that they are negotiating that is free of any baggage from the last few years and that is also not OTC levels of toxic. Debt is not bad, and for a company like ABAT, well-structured long-term debt non dilutive or at least if it is deferred dilution would be embraced by investors.

On the black mass export rule, as I figured since this is fairly new, it was a rush to submit, and now the Department of Commerce has to figure it all out; remember, they are using the DoD framework for a export restriction. But overall I am not really worried about it, but it does bring up something that I talked about in the chat during the call.

It was clear that the company was taking things slow, and to be honest, I think the Ascend Elements bankruptcy scared the bejesus out of the sector. Li-Cycle was kind of a given, but Ascend was a different story, and even with the brilliant legal moves by Ascend’s counsel, the company was still liquidated.

So I have a feeling ABAT was content to let the recycling vertical grow organically, use its profits to help expand and build out the platform, and let Tonopah work itself out. Grow but don’t overreach or over extend itself.

The BIS rule has changed that, and they are now at a crossroads: pivot away from recycling or at least downgrade its importance in the company, or make a push forward and get moving on battery grade. I think that ties into the debt that we may be seeing them take on.

Outside of that, the overall financials are for a speculative startup that is also a junior; unique but also nominal I think is the best phrasing to use here. Having a positive gross margin on black mass production is a great start, but do not expect that to stick around once they start into battery grade, well at least for a while. Once they start moving again, they are going to wreck that gross margin.

But that does bring up something that was kind of buried in the 10-K:

“an increase in legal expenses of $0.5 million related to site selection,”

Now then, I am sure they had legal expenses for the Ascend Elements bankruptcy; they were just trying to use a clear path argument to be declared the winner of the auction for the Kentucky property. But they also most likely had legal expenses for the lot next to the TRIC facility. But not $500,000 worth of legal expenses. Could they be close to picking a site for the second facility? That seems logical to me.

As for it being the Kentucky property from the Ascend bankruptcy? If it is, it better be Dollar Store prices and they are able to leverage a good portion of the DOE grant for it right off the bat.

The property and equipment table in the 10-K: before I was always saying cash COGS was where we needed to look at to see how the company was doing; now they have progressed far enough that table will be a good metric to see where they are at.

The big thing here is the construction in progress jumped almost $4 million while equipment dropped by $1.3 million. Speculation is they are working on getting new assets up and running, but also have not added enough new equipment, and depreciation is now eating into the value of that equipment.

This just supports the theory that they were content to let the recycling vertical continue operating while just adding upgrades for efficiency with no real push to expand it.

Beyond that, if you listened to the last earnings call, there really was not much new: some pomp and circumstance with the DOE visiting the TRIC facility, and he did actually go into some detail about NEPA, which was nice since the PR that they released talking about the final step needed to start the NEPA review, the BLM accepting the Mine Plan of Operations, didn’t include it all.

As for any recent FOIA requests, I think Tiffiany has gotten better at making sure that confidentiality agreements are in place, so there have been no new documents on that front.

The shareholders meeting is in November, so I guess we will talk about American Battery Technology Company again in November. As always, however, if you have a question send it my way. I may not be able to answer it or give you an answer that you want, but I will do my best to answer it factually.

If you found this article valuable, consider becoming a subscriber. The Critical Materials Bulletin is supported by readers, and for $5 a month or $55 a year you can help fund research that produces clear, no nonsense reporting that informs and advances the discussion on critical materials and battery metals.

Subscribe now

Alternatively, if do not want to commit to a subscription, you can instead buy Abe a treat or two. And in doing so you can help support my goal of taking the Critical Materials Bulletin on the road, to visit these facilities as they launch, and to continue my conversations with these companies in person.

Buy

Abe a Treat

DISCLAIMER: This article should not be construed as an offering of investment advice, nor should any statements (by the author or by other persons and/or entities that the author has included) in this article be taken as investment advice or recommendations of any investment strategy. The information in this article is for educational purposes only. The author did not receive compensation, from any of the companies and or persons mentioned to be included in the article.

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The Bureau of Industry and Security (BIS), an agency in the Department of Commerce, issued a new temporary rule, the Directive Allocation Order and Additional Requirements for Recoverable Critical Minerals and Materials, which provides a legal definition of black mass within the context of the rule.

For purposes of this Directive Allocation Order, ‘black mass’ means any shredded lithium-ion battery scrap that contains cathode material (which may include lithium, cobalt, nickel and manganese), anode material (graphite, silicon) or other residual battery cell materials.

While that definition explains what black mass is made of, it doesn’t show why it’s critical to the domestic supply chain or where and how it fits into the lithium-ion industry.

A recycler’s feedstock comes from two main sources: end-of-life batteries, or manufacturing scrap generated during production. Manufacturing scrap is further split into two categories: dry scrap (foil clippings and components produced before electrolyte is added) and wet scrap (material rejected after the electrolyte is injected).

Unlike what the general public believes, while the electrolyte contains lithium, it is not the lithium itself that poses the highest safety risk during recycling. Rather, the electrolyte itself does. When heated or exposed to air and moisture, the chemicals in the electrolyte break down into toxic, flammable gases. The severity varies based on chemistry and state of charge.

High-nickel versus lithium iron phosphate chemistries produce different gas profiles. State of charge determines not just how much gas is produced, but which gases and at what concentrations, with specific test data showing that lower state of charge thresholds in chemistries like lithium iron phosphate can yield distinct toxic gas concentrations compared to higher-charged ternary cells.

However, you can’t just crack open a battery, dump the contents into a bucket, and feed the materials into a lithium-ion production line. The materials are physically and chemically locked into complex structures. That is where the mechanical component of lithium-ion recycling comes into play. After disassembly, the cells are shredded, and that is when the black mass is created.

But why shred?

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Section 1412 of the FY2026 NDAA expands the Strategic Materials Recovery and Reuse Program for recycling and recovery of critical minerals. The DOI issued a Secretary’s Order to streamline regulations on recovery from mine waste. All of this points toward material recovery as part of the strategy to reduce the dependence on foreign critical minerals.

When it comes to the Department of Energy, the agency long positioned as the primary source of funding and guidance for critical materials, is now taking a back seat. They are providing funding to expand and develop materials from secondary sources, but most of this targets new technologies and pilot programs rather than commercial scale facilities.

After Ascend Elements and a few other projects, it seems that outside of nuclear and fossil fuels, the current administration’s DOE has lost its appetite for funding projects that utilize unconventional resources.

But beyond funding, for lithium-ion recycling, there is a problem buried in federal waste regulations, Representative Mariannette Miller-Meeks (R-IA) stated:

End-of-life batteries and scrap materials are largely sent overseas, often to China, for processing. Our own regulatory scheme under RCRA is contributing to this.

The way these rules are written, they inadvertently promote, due to financial reasons, the export of much-needed battery materials instead of allowing them to be recovered and reused in the US, creating both economic and national security concerns.

This is a real-world example of how one outfit, American Battery Technology Company, is running into that regulatory wall.

ABTC:

We had asked about requirements for a destination facility on our last call, is there any further information on this process?

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First, what do they do? Well, this links back to something I posted about last week. Blue Whale Materials produces black mass from end-of-l…

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