[brian_]

While a manufacturer (of battery-electric or ICE-equipped vehicles) normally uses components from other companies, they produce an operating vehicle; it is the product, not the sources of components, which define the status of "vehicle manufacturer". Companies which make chassis-cab trucks and stripped chassis for motorhomes or other specialty vehicles are considered manufacturers of "incomplete vehicles", which are functional vehicles but not useful for the intended purpose until completed with a body.

I doubt that a kit car company would qualify as a "vehicle manufacturer" because their product is not an operable vehicle, and I suspect that they don't want to be legally considered vehicle manufacturers due to the regulatory requirements of that business. As a practical issue, the kit car company could sell a kit with a complete structure, suspension, and even body, and has no control over what powertrain it receives, so they could manufacture an incomplete vehicle without even knowing whether it will be an EV or not... and that seems likely to be problematic.

In general I would expect the purchaser/builder to be the designated manufacturer of any vehicle built from a kit, whether that is a car or an airplane. In aircraft, they're called "amateur-built", because the vehicle manufacturer is the owner/builder, not the kit manufacturer.

 

[brian_]

... If the NHTSA is convinced, the IRS portion should be trivial.

I understand the kit car logic, and perhaps the automotive regulations can be handled, but I'm not convinced that the tax benefit for EV conversion automatically follows. If the intent of the tax credit is to replace ICE vehicles with EVs, then scrapping an EV to get the parts for a conversion (instead of fixing the EV) would not meet that intent - the conversion should net add an EV, by using new rather than salvaged parts. Of course, logic does not always determine government actions.

 

[brian_]

True, but using parts from a wrecked EV off the road to put a conversion back on the road results in a plus 1 result.

Ideally, yes. Would using the same parts to put a production EV with a failed battery or inverter back on the road qualify, since it is also a plus 1 change from not using the wrecked parts or fixing the failed EV? Not likely. It's an interesting issue of public policy.