- It is not a specified foreign entity or a foreign-influenced entity, including through ownership, board or executive appointments, debt or licensing agreements.
- For the product and period above, the share of direct material cost (including freight and tariffs) not attributable to a prohibited foreign entity is:
FEOC Certificate Exchange
Since 2026, US battery tax credits depend on proof that enough of a product's cost does not come from prohibited foreign entities (FEOC). Today that proof moves by email and spreadsheet, one customer at a time. We are piloting a neutral exchange where a supplier fills it in once and releases it to the buyers it chooses.
If you are a supplier
- Every customer sends its own FEOC questionnaire.
- You must chase your own suppliers for their proof.
- Customers ask for cost detail you would rather keep private.
If you are a buyer or developer
- Your 45X or 48E credit depends on signed supplier certificates.
- Anything you cannot trace counts against you.
- Investors, lenders and insurers ask for the same proof again.
How it will work
- Buyer1 · AskA buyer invites its supplier by email. There is no directory to browse.
- Supplier2 · Fill in onceOwnership, products and cost split. Ask your own suppliers for their proof in one click.
- Battery Pulse3 · CheckIdentity, ownership screen, the arithmetic and any missing links in the chain.
- Supplier4 · Sign and chooseYour officer signs. You pick each buyer and what it sees. Costs stay private by default.
- Buyer5 · ReceiveThe result and signed certificate for its tax file, kept for six years.
The bar rises every year
| Non-FEOC share needed | 2026 | 2027 | 2028 | 2029 | 2030+ |
|---|---|---|---|---|---|
| Battery components (45X) | 60% | 65% | 70% | 80% | 85% |
| Storage projects (48E) | 55% | 60% | 65% | 70% | 75% |
What the pilot is, and is not
- Free for pilot participants in early 2027.
- About 10 suppliers and 2 buyers, on real requests.
- Suppliers sign their own certificates. Battery Pulse records, checks and shares them; it does not certify compliance or give tax advice.
- Certificate wording is being reviewed with tax counsel; see the sample certificate below.
Your data, your control
- You decide which buyer sees which certificate, product by product. Nothing is shared until you release it.
- Your cost breakdown and your own supplier names stay private unless you choose to share them.
- You can withdraw any buyer's access at any time. Every view is logged, and you can see the log.
- No directory of companies. No one can search for you or browse your records.
- We never sell or share company-level data. Only anonymous totals from five or more firms are ever published.
How we will protect it
- Encryption of all data in transit and at rest.
- Company-email sign-in with two-factor authentication; access limited by role.
- Signed documents kept unaltered, with version history, for at least six years.
- SOC 2 Type II and ISO 27001 planned: independent audits before the exchange holds production data.
What a buyer receives: a sample certificate
Supplier certification · IRS Notice 2026-15
Prohibited foreign entity status and material assistance cost share
Supplier
Northline Anode Materials, Inc.Tax ID (EIN)
[XX-XXXXXXX]Product
NL-G20 coated spherical graphitePlant
Toledo, Ohio, USAPeriod covered
Shipments 1 Jul – 30 Sep 2026Released to
Lakeshore Cell Co. onlyThe supplier certifies that:
72.4%Clears the 45X bar for battery components in 2026 (60%) and 2027 (65%). Inputs without supplier proof (2 of 11) are counted as FEOC.
Basis: interim method under IRS Notice 2026-15. Relies on 9 upstream supplier certificates held in the Battery Pulse vault; their names and costs are withheld from the recipient at the supplier's choice.
Declaration: Under penalties of perjury, I declare that I am authorized to sign for the supplier and that, to the best of my knowledge and belief, the information in this certificate is true, correct and complete.
[Signature] · [Name], Chief Financial Officer
Signed 16 Oct 2026
Retain until 31 Dec 2032 (supplier and recipient)
Would your company take part?
We are looking for cell, module and materials makers, storage integrators and developers. Tell us:
- Whether you would join the pilot as a supplier, a buyer, or both.
- Who at your firm handles FEOC or customer compliance requests.
In the form, write "FEOC pilot" and the name of the right contact. Please use a company email address.