FEOC Compliance in 2026: What It Is—and Why “Compliant” Panels Are Almost a Myth

Updated: Feb 19, 2026
6 min

If you work in U.S. solar today, you’ve likely seen a steady stream of FEOC compliance news circulating through industry emails, webinars, and supplier decks. By 2026, FEOC compliance is no longer optional. And yet, if you ask ten suppliers whether their panels are “FEOC compliant,” you’ll often get ten confident yeses—and almost none of them will be fully true.

This article is not about marketing claims or reassuring labels. It’s about what FEOC actually means, what the FEOC compliance requirements really say, and why genuinely compliant solar panels are still exceptionally rare in today’s market.

If you’re an installer, EPC, or commercial buyer trying to future-proof projects and protect incentives, this is information you cannot afford to gloss over.

Key takeaways

FEOC compliance becomes critical in 2026, directly affecting eligibility for major federal tax credits and incentive programs.
“Assembled in the USA” does not equal FEOC compliant; upstream supply-chain control matters far more than final assembly.
China still dominates critical solar components, including cells, wafers, polysilicon, and manufacturing equipment, creating widespread FEOC exposure.
There is no official FEOC compliance certificate—most claims rely on supplier affidavits and legal interpretation, not government validation.
Many “compliant” claims are partial or forward-looking, and may not hold up under future audits.
Risk is shifting downstream: installers, EPCs, and project owners—not manufacturers—bear the financial consequences of noncompliance.
Truly FEOC-free panels are rare and costly, with limited availability and longer lead times.
Good-faith compliance matters: transparent documentation and due diligence will be critical in audits, even if exposure cannot be fully eliminated today.
The safest strategy is verification, not trust—buyers must ask detailed supply-chain questions and document every claim

What Is FEOC, Really?

FEOC stands for Foreign Entity of Concern, a designation defined under U.S. law, primarily through the Inflation Reduction Act and subsequent federal guidance.

A Foreign Entity of Concern generally includes companies that are:

Owned by, controlled by, or subject to the jurisdiction of China, Russia, Iran, or North Korea
Or materially dependent on those entities for critical components, intellectual property, or manufacturing control

In solar, the issue is not simply where a panel is assembled. It’s who controls the upstream supply chain. That distinction is at the center of most confusion—and much of the misleading information found in FEOC compliance news today.

Why FEOC Matters in 2026

Beginning in 2026, FEOC restrictions will directly impact eligibility for:

The Advanced Manufacturing Production Credit (45X)
Investment Tax Credit (ITC) domestic content adders
Certain federal, state, and utility-level incentive programs

In practical terms, if a solar product is determined to involve a Foreign Entity of Concern, it may disqualify an entire project from key tax benefits—even if the modules are assembled in the United States.

This is no longer theoretical. Developers, financiers, and auditors are already preparing to apply far deeper scrutiny to supply chains as FEOC compliance requirements come into force.

FEOC Compliance: The Reality Heading Into 2026

What the Market Says

“U.S.-made”
“FEOC compliant”
“Domestic content eligible”

What the Supply Chain Often Looks Like:

➡️ Cells: China-linked
➡️ Wafers: China-linked
➡️ Polysilicon: China-linked
➡️ Manufacturing equipment & IP: China-linked

Even when:

Modules are assembled in the U.S.
Assembly occurs in free trade zones
Domestic labor is used

FEOC exposure often remains upstream.

Assembly vs. Manufacturing (This Is Where Confusion Happens)

Assembly

Import cells
Add glass, frame, junction box
Final assembly in the U.S.

✔️ Acceptable for marketing
❌ Usually insufficient for FEOC compliance

Manufacturing

Cell origin
Wafer and polysilicon sourcing
Ownership and control of production

➡️ If the cells are FEOC-linked, the module is still exposed—regardless of where it’s assembled.

There Is No Official “FEOC Certificate”

There is currently no government-issued FEOC compliance certificate.

Compliance is evaluated through:

Supplier affidavits
Bills of materials
Chain-of-custody documentation
Legal interpretation of ownership and control

⚠️ As a result, many claims seen in FEOC compliance news today are:

Self-declared
Forward-looking (future sourcing)
Based on narrow interpretations that may not survive an audit

Who Actually Carries the Risk?

Not the manufacturer
Not the distributor

➡️ The installer, EPC, or project owner claiming the tax credit

Most suppliers are not acting in bad faith. They’re operating in a gray area with evolving FEOC compliance requirements. But once enforcement tightens in 2026, that gray area becomes financial exposure for the party claiming compliance.

What to Ask Solar Panel Suppliers About FEOC Compliance

If a supplier claims FEOC compliance, ask direct, specific questions:

Where are the cells manufactured—not just the modules?
Who owns or controls the cell and wafer manufacturing entities?
Can you provide a bill of materials and full chain-of-custody documentation?
Is compliance based on current sourcing or future plans?
Are any critical components licensed from or produced using Chinese IP or tooling?
Will you provide written affidavits supporting your FEOC claims?
If audited, who assumes the financial and compliance risk?

In 2026, documentation and transparency will matter far more than marketing labels.

What Installers and EPCs Should Be Doing Now

Stop asking whether a product is “FEOC compliant” and start asking where the cells are made, who owns the manufacturer, and how the supply chain is documented. Preserve all correspondence and documentation—even partial transparency demonstrates good-faith due diligence. Be honest with customers about uncertainty rather than over-promising compliance. And prepare for trade-offs: FEOC-reduced panels often come with higher costs, longer lead times, and fewer brand options.

That is not a failure of procurement—it is the reality of the current market.

The Bottom Line

FEOC compliance is not a box to be checked; it is a supply-chain problem the U.S. solar industry has not fully solved. Truly FEOC-compliant panels remain rare, and many products labeled as compliant rely on partial mitigation rather than full independence from FEOC influence. As enforcement tightens in 2026, assumptions will no longer be enough—only documentation, transparency, and due diligence will protect projects from financial risk.

Tatiana Ivanova

Author

With a degree in Linguistics, Tatiana uses her vast experience in technical translation to deliver complicated concepts in simple words. She joined the company in 2020 as a contributing writer to become the person to influence Blog’s development.