As federal guidance around Foreign Entities of Concern (FEOC) evolves, developers, investors, insurance providers, IPPs and capital partners from large utility scale to C&I to community solar need a solar manufacturing partner that removes doubt and delivers clarity. At ES Foundry, we proactively meet — and in many areas exceed — proposed FEOC restrictions so you can move forward with confidence.*
What's New
Treasury and the IRS have issued interim FEOC guidance under Notice 2026-15, 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, use interim safe harbors and apply the rules until additional safe harbor tables and regulations are published. In practice, that creates a more usable compliance framework while raising the bar for supply chain visibility, documentation and substantiation.
What Is FEOC — and Why Does It Matter?
FEOC stands for Foreign Entity of Concern. It's a term used to describe organizations or entities that are owned, controlled or subject to the jurisdiction of a foreign government that is designated as a “covered nation”. These are currently China, Russia, Iran and North Korea. Current policies allow bonus incentives for projects using U.S.-made products — but not if those products involve a FEOC. Under the strictest proposed definitions, a FEOC includes any company:
How ES Foundry Meets FEOC Compliance Requirements
We don’t just claim compliance — we demonstrate it across every layer of our operations and supply chain.
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Get the Details: Download Our FEOC-Compliant Solar Cells Datasheet
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FEOC Compliance FAQ
The term refers to any entity that is owned, controlled or subject to the influence of the governments of China, Russia, Iran or North Korea. This includes state-owned enterprises, companies with board members or executives linked to those governments and foreign companies that provide sensitive technology or materials.
Projects using FEOC-linked components may be ineligible for the 48E and the domestic content bonus. They may also face higher risks, delays and reputational scrutiny.
Yes. We meet or exceed all current and proposed FEOC compliance guidelines. Our ownership, funding, executive team, board structure, IP and supply chain are entirely free from FEOC involvement.
We have a dual-sourcing strategy in place for 2025, with confirmed non-FEOC supply for 2026 and beyond. This transition ensures your projects remain eligible and protected as standards tighten.
Secure Your 2026 Cell Domestic Content Supply
Demand for compliant U.S.-made solar cells is already outpacing supply. Lock in your cell 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 capacity and secure your pipeline.
* The information provided on this page is based on our current understanding of the law and is intended for informational purposes only. We are not offering legal advice, nor should any of the content be interpreted as such.