Foreign Entity of Concern (FEOC) compliance

Understanding Foreign Entity of Concern (FEOC)

For quick reference, visit the Enphase “FEOC Compliant” products page

As of July 4, 2025, the One Big Beautiful Bill Act (H.R. 1 119th Congress) (OBBBA) requires that solar and battery energy storage facilities that commence construction after December 31, 2025 comply with certain foreign entity of concern (FEOC) requirements in order to earn U.S. federal income tax credits under Section 48E or Section 45Y of the Internal Revenue Code.

The FEOC rules apply to prohibited foreign entities (“PFEs”). In general, a PFE is a citizen or national of China, Russia, Iran, and North Korea (each a “Covered Nation”) or an entity that is owned by, controlled by, or otherwise subject to the jurisdiction or direction of a government of a foreign country that is a Covered Nation.

Enphase has conducted an in-depth evaluation of its supply chain and manufacturers and has determined that certain of its microinverters and battery energy storage products are “FEOC Compliant”.

Enphase deems microinverters for incorporation into rooftop solar facilities “FEOC Compliant” when:

the microinverter is manufactured by a person that is not a PFE,
the PCBA in the microinverter is not manufactured by a PFE,
the enclosure is not manufactured by a PFE.

Enphase microinverters have only one PCBA and do not utilize thermal management systems.

Enphase deems battery energy storage products as "FEOC Compliant" when:

the incorporated inverter/converter is manufactured by a person that is not a PFE,
the PCBA and enclosure in the inverter/converter are not manufactured by a PFE,
the Battery Container/Housing is not manufactured by a PFE, and the enclosure, battery management system, and thermal management system are not manufactured by a PFE.

For this purpose, we have considered whether an item is manufactured and by whom solely for purposes of 26 U.S.C. Section 7701(a)(51) and evaluated only those items that appear in Section 5.06 (in regard to microinverters) of IRS Notice 2025-08 and Section 7.02 (in regard to battery energy storage systems) of IRS Notice 2025-08.

These rules and regulations are complex and subject to change. Further, the application of these rules and regulations is highly fact specific, including with respect to how a particular item of equipment is used. The information herein is general in nature and premised specifically on the definitions of “FEOC Compliant” and “FEOC Compliant” as set forth above. Enphase cannot assure and is not responsible for any particular U.S. federal income tax result of using an Enphase microinverter or battery in any energy generation facility. You should seek appropriate professional advice as to how these rules and regulations apply to your situation. Enphase assumes no obligation to update this information or any other information provided on this page or related to whether any specific Enphase product SKU(s) are “FEOC Compliant”, please refer to the latest rules, events, or any regulatory action.

To quickly verify whether specific Enphase product SKU(s) and serial numbers are “FEOC Compliant”, installers and finance partners can use the online “FEOC Compliance” Tool. Distributors can access a dedicated version of the Tool by signing into their distributor portal.

Please note that the information provided by the Tool is based upon the various rules and regulations in effect, as well as information available, as of the date you submit your query.

FAQs

Enphase is introducing the “FEOC Compliance” Tool to provide transparency in the supply chain and to help our customers determine whether the Enphase microinverters and batteries they have purchased are “FEOC Compliant”.

Enphase treats microinverters for incorporation into rooftop solar facilities as “FEOC Compliant” when:

(1) the microinverter is manufactured by a person that is not a PFE,

(2) the PCBA in the microinverter is not manufactured by a PFE,

(3) the enclosure is not manufactured by a PFE.

Enphase microinverters have only one PCBA and do not utilize thermal management systems.

Enphase treats battery energy storage products as “FEOC Compliant” when:

(1) the incorporated inverter/converter is manufactured by a person that is not a PFE,

(2) the PCBA and enclosure in the inverter/converter are not manufactured by a PFE,

(3) the Battery Container/Housing is not manufactured by a PFE, and the enclosure, battery management system, and thermal management system are not manufactured by a PFE.

In general, the term “PFE” means a “prohibited foreign entity” as defined under 26 U.S. Code § 7701(a)(51), which is a citizen or national of China, Russia, Iran, and North Korea (each, a “Covered Nation”) or an entity that is owned by, controlled by, or otherwise subject to the jurisdiction or direction of a government of a foreign country that is a Covered Nation.

I have purchased microinverters and/or batteries from Enphase. Where can I check the percentage of direct costs for my microinverter or battery that are attributable to PFEs?

When you enter the serial number of your Enphase microinverter or battery into the Enphase “FEOC Compliance” Tool, the system will tell you whether the item is “FEOC Compliant”. If you need more information, please contact your Enphase sales representative.

If a product is not labeled “FEOC Compliant”, that means that the product does not comply with the requirements of “FEOC Compliance” as described in detail above.

Our “FEOC Compliant” Microinverters and the “FEOC Compliant” battery energy storage products (also referred to as Battery Electric Storage System or BESS) are manufactured to Enphase specifications, using our rigorous quality control standards. We have worked with our lawyers and suppliers to evaluate Enphase's status for FEOC purposes, our manufacturers' status for FEOC purposes, and how our “FEOC Compliant” microinverters and the “FEOC Compliant” BESS are manufactured.

Enphase is actively transitioning its sourcing practices to avoid providing any products that are not “FEOC Compliant”. During this transition period, both “FEOC Compliant” and non-compliant Enphase products may be available. Our “FEOC Compliance” Tool helps to distinguish between these products transparently.

No, both types of products offer the same quality and performance. The FEOC rules have no bearing on the performance of the products.

Yes. Non-compliant products will function the same way technically. The FEOC rules have no bearing on the functionality of the products.

Yes. FEOC compliance does not affect the Enphase limited warranty or technical support. All products purchased through authorized channels continue to be fully supported by Enphase.

This website is updated regularly to reflect products that have been manufactured. However, Enphase represents that the statements made in the “FEOC Compliance” Tool is accurate only as of the date they are made (which is indicated in the “FEOC Compliance” Tool).

Currently, the webpage supports individual serial number lookups. For large-volume verification, distributors and partners can contact their Enphase account representative for support.

You should discuss with your own U.S. federal income tax attorney or accountant.