Credit Deep-Dive · CD-TC-CA-CTM-2026
Manufacturing & Minerals 30% Refundable Deep-Dive · August 2026

The Manufacturing ITC: 30 Percent, No Labour Strings

The only clean economy credit with no wage or apprenticeship conditions pays 30 percent on machinery for clean technology manufacturing and critical mineral processing — and Bill C-15 nearly doubled the mineral list while relaxing the polymetallic test.

By Koorosh Behrang · Founder, Climate Decode · · 7 min read

CTM ITC · BY AVAILABLE-FOR-USE YEAR % OF CAPITAL COST 30%TO 203120%203210%20335%2034 MINERALS ELEVEN five added by C-15 LABOUR RULES NONE full rate without election POLYMETALLIC >50% TEST primarily-qualifying output now works NO LABOUR CONDITIONS · ELEVEN CRITICAL MINERALS

At a Glance — Where Things Stand

The rate

30%

Refundable, on machinery and equipment available for use through 2031 — stepping 20/10/5 across 2032–34.

The scope

Making + mining

Manufacturing of clean technologies, and extraction and processing of eleven listed critical minerals.

The simplicity

No labour rules

Alone among the five credits — the full rate needs no wage or apprenticeship election.

Our View

CTM is the supply-chain mirror of the US 45X, with a different philosophy: Canada pays 30 percent of the machine, the US pays per unit that comes off it. For a battery, solar or processing plant the Canadian structure de-risks the build; the American rewards throughput. Operators with siting flexibility should model the credits as competing offers — and note that CTM carries no foreign-content machinery today, while 45X now runs on content ratios.

The C-15 changes are worth real money in mining: five added minerals — antimony, indium, gallium, germanium, scandium — and a primarily-qualifying test that lets polymetallic sites claim where qualifying output exceeds half of commercial value, with a binding valuation-method election and an independent engineer’s certification. Sites written off as ineligible under the old all-or-substantially-all test deserve a second look.

1

What Qualifies

  • Machinery and equipment used all or substantially all for manufacturing or processing clean technologies — solar modules, wind components, batteries and battery materials, ZEVs and their components, electrolysers, nuclear fuel and heavy water among them
  • Property for extraction and specified processing of eleven critical minerals: lithium, cobalt, nickel, copper, rare earth elements, graphite — plus antimony, indium, gallium, germanium and scandium since Bill C-15
  • Polymetallic operations where qualifying materials are primarily (more than 50 percent) the output by value, under a fair-market-value or five-year safe-harbour pricing election certified by an independent engineer or geoscientist
  • Refurbishment property, added by C-15 in parallel with the Clean Technology credit

Claims run through Schedule 78 mechanics on the T2 return, refundable, with the same one-property-one-credit rule as the rest of the stack and stacking preserved with Atlantic ITCs and accelerated CCA.

2

Rates and Phase-Down

Available for useRate
Jan 1, 2024 – Dec 31, 203130%
203220%
203310%
20345%
After 20340%

Note the effective-date split inside C-15: the five added minerals apply to property acquired and available for use from November 4, 2025, while the polymetallic relaxation reaches back to the start of 2024 — mixed-output sites may have claimable history under one change and only forward eligibility under the other.

Eleven minerals, a relaxed polymetallic test, and no labour conditions. Re-screen the asset base against the C-15 list.

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3

The Strategic Context

The manufacturing credit sits inside a larger 2025–2026 minerals push: a $2 billion Critical Minerals Sovereign Fund, an expanded exploration tax credit, and Buy-Canada procurement policy under design. For US-linked supply chains, the interplay with 45X’s content ratios matters most — Canadian-processed minerals and components are “non-prohibited” inputs for American buyers computing material-assistance ratios, which quietly makes Canadian capacity a compliance asset for the US market, not just a subsidised competitor.

4

Stacking With Clean Fuel Programmes

The CTM ITC sits one step upstream of the fuel programmes: the electrolysers, storage systems and battery components coming off a credited line are the equipment inside projects that earn CFR, BC LCFS and California LCFS credits on their output. The manufacturer’s capital credit takes nothing from the project owner’s ITC or from the operating credits downstream — the stack runs the full length of the supply chain.

For US-linked chains there is a second connection: Canadian-processed minerals and components count as non-prohibited inputs in American 45X and 48E content ratios, which makes CTM-credited capacity a compliance asset for the US market as well as a subsidised cost base at home.

Climate Decode · Advisory

Manufacturing or minerals capital on the table?

Eligibility screening, valuation elections, claim files and the cross-border 45X comparison — one workstream.

Sources

This article is general information on United States and Canadian tax law as at the date of publication, not legal or tax advice. Filing positions require the opinion of qualified tax counsel.

About the Author

Koorosh Behrang — Founder at Climate Decode, Tax Credits Series author

Koorosh Behrang

Founder, Climate Decode

Founder of Climate Decode with more than 10 years of experience across decarbonization strategy, corporate sustainability, Net Zero target setting, and compliance carbon markets. His work centres on the interaction between decarbonization pathways and regulated carbon systems.

Koorosh has worked extensively across programs including WCI, Ontario EPS, Alberta TIER, BC OBPS, Canada’s Clean Fuel Regulations, the EU ETS and FuelEU Maritime, and leads the firm’s Canadian clean economy ITC work, including 45V clean hydrogen advisory covering eligibility, carbon intensity computation and annual management.

Speak to Koorosh → LinkedIn →

© 2026 Climate Decode · Credit Deep-Dive · Reference CD-TC-CA-CTM-2026

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