IGNITE JUL 25 - Staying Ahead of FEOC: What It Means for U.S. Solar—and How We're Responding

Conrad (Chi) Ning
Jul 30
4 min read

With the rollout of the new “Foreign Entity of Concern” (FEOC) rules this month, there’s understandable concern across the renewable energy industry—especially among developers and manufacturers looking to qualify for federal incentives. At Imperial Star Solar, we want you to know where things stand, what’s changing, and how we’re staying on top of it.

What Are FEOC Rules?

The FEOC designation was created to prevent companies tied to certain foreign governments—most notably China, Russia, North Korea, and Iran—from claiming key tax credits under the Inflation Reduction Act (IRA). These restrictions now apply to a wide range of renewable energy tax benefits, especially the technology-neutral 45Y and 48E credits, as well as the 45X manufacturing credit.

Projects or manufacturers using components or materials from FEOC-linked entities—or who give up contractual control to such entities—risk being disqualified from these credits.

Key things to know:

The rules apply starting in tax years after July 4, 2025.
Projects already underway—and those starting construction before July 2026—may still qualify under legacy credit systems (45 or 48).
The biggest impact right now is on sourcing, supply chain reliability, and contract structures going forward.

The Industry View

There’s been strong pushback from both U.S. manufacturers and clean energy developers. The immediate concern is clarity: what exactly qualifies as “foreign control”? How deeply will regulators probe contracts, sourcing, or investment history?

And of course, there’s legitimate concern over how FEOC rules may slow down or increase the cost of new energy infrastructure—especially for projects already on tight timelines.

Our Response - and What It Means for You

We’ve been proactive. Over the last year, we’ve been preparing for these changes and refining our sourcing practices. Here’s how we’re responding:

Supply Chain Audits: We’ve conducted thorough reviews of our suppliers and material sources to ensure that we are compliant—and will continue to be as the regulations take effect.
U.S.-First Sourcing: Our partnerships already prioritize U.S.-based and allied manufacturers. We’ve expanded those relationships deliberately to reduce exposure to FEOC risks.
Contractual Safeguards: We’re working closely with legal and tax experts to ensure that our project-level contracts maintain clear and compliant control structures.
Clear Communication: Developers and partners deserve straight answers. We’re keeping our customers up to date—whether it’s through updated documentation, supply attestations, or timelines that help keep your project eligible.

Looking Forward

Big federal changes are around the corner for solar tax credits and FEOC compliance. By August 18, the Treasury will release new rules tightening what it means to “begin construction” and enforcing tougher FEOC requirements. Expect that the old “safe harbor” shortcuts may not be enough—real, substantial physical work will likely be required to qualify for ITC and PTC.

Key Points:

Projects starting after July 4, 2026, lose ITC/PTC eligibility unless finished by year-end 2027. If you started by July 4, 2026, you get more flexibility.
Stronger FEOC supply chain documentation will be required.
The safe harbor rules are getting stricter—advance payments or minor site work might not cut it.

Our Commitment:

Imperial Star is closely tracking these changes. We’ll keep you updated and make sure your modules come with the right documentation. Need advice or clarity? We’re here. Start project planning now so you don’t get caught by surprise.

Built for Scale: Manufacturing Power Few Can Match

Photo: Inside Imperial Star Solar's Houston-based solar module factory

At a time when the market is demanding more American-made solar than ever, Imperial Star Solar is delivering at a scale few can match. Our Houston facility is currently running at 2 gigawatts (GW) of annual production capacity—not theoretical, not future-planned, but active, proven throughput built to meet today’s project demands.

And we’re not slowing down. By 2026, we’re expanding to 3.5–4 GW. That’s nearly double our current capacity, purpose-built to support developers, EPCs, and long-term partners with the volume and reliability this industry now requires. Unlike many others, we don’t just talk capex and capacity—we’re running production lines day in, day out, with real jobs and real modules built right here in the U.S.

What Sets Us Apart

High output, real volume: We’re one of the few U.S. manufacturers actually hitting GW-scale delivery today.
Expansion underway: Projects you’re planning for next year and beyond? We’ll have the scaled-up production to meet them on time.
Unmatched transparency: We welcome customers and partners to visit our Houston factory—talk to our team, inspect our lines, and see firsthand what true stateside manufacturing looks like.

If you’re ready to partner with a manufacturer that delivers more than just promises, we’d be glad to show you around. Come see what 2 GW of grit—and a 4 GW future—really looks like.

We're Hiring — Grow With Imperial Star Solar

As we scale annual capacity in Houston, we’re adding to our team. If you want to be part of real U.S. solar manufacturing—on the shop floor, in supply chain, or in sales—we want to hear from you.

Why Join Imperial Star?

Steady work with a growing American company
Open positions for skilled operators, logistics, sales, human resources and management
Benefits, and room to advance
Help build the future of clean energy, right here at home

Ready to make an impact? Check out our open roles and apply today—let’s build the future, together.

Apply Now

Upcoming Industry Events

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