FEOC Compliance | Non-FEOC Certified U.S. Manufacturer

What's New: IRS Notice 2026-15

Treasury and the IRS have issued interim FEOC guidance giving developers and manufacturers a clearer framework for evaluating whether a project or component received material assistance from a Prohibited Foreign Entity. The notice outlines how to calculate the Material Assistance Cost Ratio (MACR), use interim safe harbors, and apply the rules until additional safe harbor tables and regulations are published. Read the full guidance →

Understanding the Rules

What Is FEOC — and Why Does It Matter?

FEOC stands for Foreign Entity of Concern. It describes organizations that are owned, controlled, or subject to the jurisdiction of a foreign government designated as a "covered nation" — currently China, Russia, Iran, and North Korea. The One Big Beautiful Bill Act (OBBBA), signed July 4, 2025, dramatically expanded FEOC restrictions — now termed Prohibited Foreign Entity (PFE) rules — to the 48E investment tax credit, 45Y production tax credit, and 45X advanced manufacturing credit.

Under the strictest proposed definitions, a FEOC/PFE includes any company that meets these criteria:

Owned or controlled — even partially — by a covered nation's government, officials, or dominant political party

With board members, executives, or 25%+ equity interest held by designated foreign entities

Incorporated in, headquartered in, or performing relevant activities within a covered nation

Providing key equipment, materials, IP, or services tied to those governments

In short: if your solar components come from a FEOC/PFE-linked supply chain, your project could lose access to 48E/45Y credits, the 10% domestic content bonus, and face heightened investor, insurance, and reputational risks.

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Our Compliance Position

How NanoPV Meets FEOC Compliance Requirements

Ownership & Leadership

Equity: FEOC ownership stake0% — Fully U.S.-owned

Board: Members from FEOC nationsNone

Executive Team: Leadership base100% U.S.-based

Incorporation: Corporate homePrinceton, NJ, USA (2005)

Financial Structure

Debt: Loans or credit from FEOC banksNone

Investment: Funding from FEOC countriesNone

Financial obligations: FEOC entitiesNone

Intellectual Property & Contracts

Licenses: Shared IP with FEOC entitiesNone

Technology: Core IP originProprietary — invented in U.S./Switzerland

Patents: IP portfolio jurisdictionU.S. patent filings

Operations & Manufacturing

Primary facility: Panel & module productionAmericus, GA, USA

Regulations: Labor & environmentalU.S. federal & state

Capacity: Current / planned250 MW → 2,000 MW

Certifications:IEC / UL / TUV / CE / RoHS

Material Sourcing

2025: Silicon & wafer sourcingNon-FEOC

2026+: Confirmed supply contractsNon-FEOC only under contract

Cell technology: Core productionProprietary NanoPV TCLO / nano-Si

MACR Threshold Schedule (48E / 45Y)

Year	Non-PFE Minimum	Domestic Content Bonus	Status
2025	N/A (pre-FEOC)	40%	Safe harbor available
2026	40%	50%	Now in effect
2027	45%	55%	Fully qualified
2028	50%	60%	Fully qualified
2029	55%	65%	Fully qualified
2030	55%	65%	Fully qualified

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Get full technical specifications for NanoPV's U.S.-manufactured, FEOC-compliant solar panel lineup — from 100W thin-film to 695W modules.

Frequently Asked Questions

FEOC Compliance FAQ

What does the term Foreign Entity of Concern (FEOC) mean?

The term refers to any entity owned, controlled, or subject to the jurisdiction of a government designated as a "covered nation" — China, Russia, Iran, or North Korea. Under the OBBBA, this has been expanded into two categories: Specified Foreign Entities (SFEs), which are entities incorporated in or headquartered in covered nations, and Foreign Influenced Entities (FIEs), which have significant ownership, board, or financial ties to covered nations. Together these are now referred to as Prohibited Foreign Entities (PFEs).

How do FEOC rules impact solar tax credits?

Projects beginning construction after December 31, 2025, must meet the Material Assistance Cost Ratio (MACR) — at least 40% of manufactured product costs must be non-PFE in 2026, rising 5% per year. Projects failing to meet the threshold lose eligibility for 48E and 45Y credits. Additionally, the domestic content bonus credit (10%) requires escalating domestic content percentages starting at 50% in 2026. Using FEOC-linked components jeopardizes both the base credit and the bonus.

Is NanoPV Solar 100% FEOC-compliant?

Yes. NanoPV Technologies Inc. was incorporated in the United States in 2005 and is headquartered in Princeton, New Jersey. Our ownership, board, executive team, financial structure, intellectual property, and primary manufacturing operations (Americus, Georgia) are entirely U.S.-based with zero FEOC involvement. Our core cell technology (TCLO and nanocrystalline Si) was invented by our founder and is proprietary to NanoPV. We provide full compliance documentation and certification upon request.

What about silicon and wafer sourcing?

For 2025, we maintain a dual-sourcing strategy with both FEOC-compliant and transitional supply. For 2026 and beyond, NanoPV has confirmed contracts exclusively with non-FEOC silicon and wafer suppliers. This ensures your projects remain eligible and protected as MACR thresholds increase year over year.

What is the Material Assistance Cost Ratio (MACR)?

The MACR is the percentage of total direct costs for manufactured products in a project that are attributable to Prohibited Foreign Entities. IRS Notice 2026-15 provides the interim framework and safe harbors for calculating this ratio. Until the IRS publishes updated safe harbor tables (deadline: December 31, 2026), taxpayers may rely on tables from IRS Notice 2025-08 or supplier certifications. NanoPV provides full documentation to support your MACR calculations.

Can NanoPV help me with domestic content bonus documentation?

Yes. As a U.S. manufacturer with panels produced at our Americus, Georgia facility, NanoPV provides the certifications, cost breakdowns, and supply chain documentation needed to support domestic content bonus claims under the current safe harbor framework. Contact us for MACR support, supplier certifications, and project-specific compliance assistance.

What are the key regulatory references I should know?

OBBBA (One Big Beautiful Bill Act) — Signed July 4, 2025; expands FEOC restrictions to 48E, 45Y, 45X credits. Section 7701(a)(52) — Defines Prohibited Foreign Entities and safe harbor provisions. IRS Notice 2025-08 — Domestic content safe harbor tables (interim reliance authorized). IRS Notice 2026-15 — Interim MACR framework and safe harbors. Executive Order 14315 — Directs Treasury to issue additional guidance within 45 days of July 7, 2025. DOE FEOC Interpretive Guidance — Defines FEOC criteria including the 25% ownership threshold and jurisdiction tests.

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Lock in your panel capacity now to stay ahead of evolving policy and ensure your projects qualify for the full value of domestic content incentives. Contact us to reserve your pipeline.

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