The Department of Transportation does not decide where car companies buy parts. That job belongs to Commerce, the Trade Representative, and Congress. Sean Duffy wrote to Jim Farley anyway.
The letter is dated September 3 and runs about two pages. DOT posted it publicly on September 8. Duffy tells Ford’s CEO that the company’s recent decisions show a foundational American brand “actively intertwining its future with Chinese state-backed enterprises,” then lists the receipts: the CATL battery technology license at BlueOval Battery Park in Marshall, Michigan; the Geely joint venture in Spain; talks with BYD over hybrid components; a joint-venture framework Duffy says Farley floated at the Detroit Auto Show; and the decision to keep building certain Lincolns in China until 2030.
Ford fired back the same day, calling the letter a “wrongheaded attempt to capture headlines” and saying it contains factual errors. The company denies proposing any joint-venture framework, says the Marshall plant is Ford-owned and Ford-staffed with a limited technology license rather than a foreign-owned operation, and says the Lincoln criticism is off base.
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Here’s what the underlying documents actually show, because most of this is on the public record and nobody seems to be reading it.
The Nautilus number is worse than the letter says
Every automaker files parts-content data with NHTSA under the American Automobile Labeling Act. That filing is where the sticker on the window comes from, and it’s the single most useful document in this entire fight.
Pull the MY2026 report and find the Lincoln Nautilus. US/Canadian parts content: 10 percent. Major foreign source: China, 90 percent. Final assembly: China. Engine: China. Transmission: China.
That is not a domestic vehicle with an imported trim piece. That is an entire industrial package sitting on the other side of the Pacific, and unwinding it means qualifying a body shop, a paint shop, a 2.0-liter engine line, a transmission source and a tier-two supplier base. Four years is not foot-dragging. Four years is roughly what that takes.
While you have the file open, scroll up two lines. Ford’s own federal filing lists China as a country of origin for the Mustang’s six-speed manual transmission and for a Bronco transmission. Duffy’s letter doesn’t mention either. Scroll further and you’ll find Cadillac’s Lyriq, Optiq and Vistiq, plus the Chevy Blazer EV and Equinox EV, all showing China as their top foreign parts source at 18 percent. Mercedes lists China in the twenties and thirties on the EQ cars.
Ford is not an outlier here. Ford is the one that got a letter.
The 2030 date isn’t Ford’s date
This is the part that makes the letter awkward.
In January 2025 the Commerce Department’s Bureau of Industry and Security finalized its connected vehicles rule, which bans vehicle connectivity and automated driving software linked to China starting with model year 2027, and bans the associated hardware starting with model year 2030.
A modern Lincoln is a connected vehicle. Its telematics module, cellular radio and infotainment stack all fall inside the definition. Which means Ford’s stated 2030 exit from Chinese Nautilus production lands precisely on the deadline the federal government itself set for the hardware. Ford isn’t choosing 2030 out of thin air. It is complying with a calendar written by the same administration now complaining about the calendar.
You can argue Ford should move faster. You cannot really argue that hitting a federal deadline exactly is evidence of divided loyalty.
Licensing versus a joint venture is a real distinction
Duffy’s letter treats the CATL arrangement and the Geely arrangement as the same species of problem. They are structurally different animals, and anyone who has looked at a term sheet knows it.
Marshall is a technology license. Per Ford’s own updates from the plant, BlueOval Battery Park Michigan is running lithium iron phosphate cell production with more than 500 employees on the way to a stated 1,700, operated through BlueOval Battery Michigan LLC, a wholly owned Ford subsidiary, at roughly 20 GWh of annual capacity. CATL supplies the recipe and the process know-how. Ford owns the equipment, the building and the payroll.
Valencia is an actual joint venture. Ford and Geely announced in July that they’ll share the Spanish plant, with three Ford-branded multi-energy vehicles and two electric Geely SUVs starting in 2028, operations beginning in the first half of 2027. That one puts a Chinese automaker on a production line in Western Europe, which is a genuine strategic question. It just isn’t a US one.
Why LFP was licensed in the first place
Worth understanding the engineering, because “why not just develop it yourself” gets thrown around a lot.
Lithium iron phosphate is chemically simple and patent-expired. The hard part is manufacturing yield: cathode particle coating, electrode calendering, moisture control at the parts-per-million level, and formation cycling that determines whether your cells last 3,000 cycles or 800. CATL has spent two decades and enormous volume grinding that process down. Buying the process is a shortcut, and the alternative was importing finished Chinese cells, which is what most of the industry does.
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LFP also matters to owners in ways NMC doesn’t. It shrugs off repeated DC fast charging, tolerates being parked at 100 percent state of charge, contains no cobalt or nickel, and is far less prone to thermal runaway. It’s also heavier per kWh and unhappy in deep cold. If you buy an affordable EV in the next few years, you are probably buying LFP.
What this means if you’re shopping
Read the Monroney sticker. The parts-content block is federally mandated and it tells you final assembly country, engine origin, transmission origin and US/Canadian content percentage. It is the only line on that window that isn’t marketing.
For anyone eyeing a used Nautilus, factor in the supply chain. A vehicle at 90 percent Chinese content has a collision-parts pipeline that runs through tariff schedules and ocean freight. Longer parts waits push up rental days and repair invoices, and higher repair invoices push cars past the total-loss threshold faster. That’s a real cost that shows up in your deductible and your renewal, and it won’t change no matter how many letters get published.
CATL’s presence on the Pentagon’s list of Chinese military companies carries no import ban for automakers, which is why the letter reads as a warning rather than an order. DOT can regulate safety standards, recalls and fuel economy. It cannot tell Ford who to buy cathode powder from. That’s the whole reason this arrived as a press release instead of a rulemaking.