AVL & All Things Hardware

Add'l Details

Hyundai #1

HiS-T4**NF(BK)

FEOC Compliant ✅

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Hyundai #2

HiN-T4**NF(BK)

FEOC Compliant ✅

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FEOC Compliant ✅

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FEOC Compliant ✅

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FEOC Compliant ✅

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FEOC Compliant ✅

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FEOC Compliant ✅

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Added 12/18/25

FEOC Compliant ✅

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Added 12/18/25

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REC #1

FEOC Compliant ✅

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FEOC Compliant ✅

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FEOC Compliant ✅

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FEOC Compliant ✅

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FEOC Compliant ✅

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FEOC Compliant ✅

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Sirius #1

FEOC Compliant ✅

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Sirius #2

FEOC Compliant ✅

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Sirius #3

FEOC Compliant ✅

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Sirius #4

FEOC Compliant ✅

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Sirius #5

FEOC Compliant ✅

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Sirius #6

FEOC Compliant ✅

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Sirius #7

FEOC Compliant ✅

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Pre-approvals Fully allocated to select installers.

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SEG #1

Pre-approvals fully allocated to select installers.

SEG #2

Pre-approvals fully allocated to select installers.

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Enph #1

FEOC Compliant ✅

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Enph #2

FEOC Compliant ✅

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Enph #3

FEOC Compliant ✅

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Enph #4

FEOC Compliant ✅

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Enph #5

FEOC Compliant ✅

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Enph #6

FEOC Compliant ✅

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QInvert #1

FEOC Compliant ✅

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SE #1

FEOC Compliant ✅

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SE #2

FEOC Compliant ✅

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SE #3

FEOC Compliant ✅

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SE #4

FEOC Compliant ✅

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SE #5

FEOC Compliant ✅

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TslaInv #1

FEOC Compliant ✅

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GNRC#1

FEOC Compliant ✅

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GNRC #2

FEOC Compliant ✅

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EnpBat #1

Approved Serial Numbers begin with:

FEOC Compliant ✅

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EnpBat #2

FEOC Compliant ✅

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SE Bat#1

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Tsla Bat#1

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Tsla Bat#2

FEOC Compliant ✅

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GRCBat#1

FEOC Compliant ✅

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Franklin #1

Racking SKUs cannot come from a Prohibited Foreign Entity (PFE). Refer to calculator for specific SKUs available.

Racking SKUs cannot come from a Prohibited Foreign Entity (PFE). Refer to calculator for specific SKUs available.

Racking SKUs cannot come from a Prohibited Foreign Entity (PFE). Refer to calculator for specific SKUs available.

Racking SKUs cannot come from a Prohibited Foreign Entity (PFE). Refer to calculator for specific SKUs available.

Racking SKUs cannot come from a Prohibited Foreign Entity (PFE). Refer to calculator for specific SKUs available.

Racking SKUs cannot come from a Prohibited Foreign Entity (PFE). Refer to calculator for specific SKUs available.

Racking SKUs cannot come from a Prohibited Foreign Entity (PFE). Refer to calculator for specific SKUs available.

Racking SKUs cannot come from a Prohibited Foreign Entity (PFE). Refer to calculator for specific SKUs available.

Racking SKUs cannot come from a Prohibited Foreign Entity (PFE). Refer to calculator for specific SKUs available.

FEOC Focus

FEOC Compliance focuses on who owns and controls the companies in a supply chain. This is distinct from Domestic Content, which focuses on where equipment is manufactured. While the concepts have some practical overlap, they are distinct.

Bottom Line: FEOC provisions aim to move installations away from Chinese-owned or tied equipment manufacturers. Domestic Content compliance does not equal FEOC compliance.

Calculator

Palmetto offers a detailed eligibility calculator for admin users in our portal. Admin users can select the "Tools" dropdown.

Our AVL details approved manufactures. But specific SKUs, and their FEOC-compliance values (%) are available only in our calculator.

FEOC Goal

Starting in 2026, certain % of project value cannot be tied to Foreign Entity of Concerned (for practical purposes of residential solar equipment, this is focused on China).

This means that all installations must be FEOC compliant starting on January 1, 2026 (defined by “Install Submitted” date).

Minimum Thresholds

2026: 40% PV Only | 55% PV + Battery or Battery Only

2027: 45% PV Only | 60% PV + Battery or Battery Only

(Percentages increase by 5% each year thereafter)

PV and Battery FEOC percentages are calculated separately via the Domestic Content table from IRS Notice 2025-08

Bottom Line: in 2026, at least 40% for PV and 55% for Battery cannot be tied to a Foreign Entity of Concern."

How FEOC Works

Palmetto works directly with OEMs (manufacturers) and distributors on a robust set of qualifying paperwork and analysis. Each piece of equipment then goes through a deep diligence process with our tax partner, Deloitte. This process is robust and time consuming, requiring patience and diligence by all parties involved.

Based on federal guidelines, each piece of equipment used in solar installations is assigned a unique percentage, based on the entity which owns the manufacturing process.

That total percentage must meet the minimum threshold. Calculations are already curated for our partners. Partners will note that calculations rely on the current Domestic Content tables-- but substitute the who (FEOC) for the where (ITC-DC). Put plainly: there is overlap in the underlying calculations for determining both FEOC and Domestic Content eligibility, but this does not mean that the two are synonymous.

Partners should understand that we actively work with industry stakeholders to review compliance and make as many options available as possible, within the confines of federal law. We cannot bypass our formal review process-- this means that verbal confirmations of FEOC compliance, rumors, etc can't be considered. If some person or entity has given you an indication that a piece of equipment is compliant, but it is not showing up on our AVL or calculator- this means that the formal process has not been executed. There is no submission process required for installation partners to submit things for review into Palmetto- we handle this directly with manufacturers and our tax advisor.

FEOC Example

Achieve FEOC compliance by getting over the minimum threshold. Different equipment is assigned different percentages (based on federal guidelines), so different combinations may yield different results. Use our ITC Calculator in the portal for exact details.

[Example A]

[Example B]

For practical purposes, Palmetto will not have any non-FEOC-compliant panels on our AVL.

For Inverter, Use:

For Racking, Use:

For Module, Use

Any Domestic Content

Enphase (MLPE)

Any that is Domestic Content Qualified (Rail + Splice + Fasteners)

Any AVL Approved Module (FEOC Compliant)

Any Domestic Content SolarEdge (MLPE)

Any that is Domestic Content Qualified (Rail + Splice + Fasteners)

Any AVL Approved Module (FEOC Compliant)

Any Domestic Content

QCells (MLPE)

Any that is Domestic Content Qualified (Rail + Splice + Fasteners)

Any AVL Approved Module (FEOC Compliant)

Tesla PW3 Domestic Integrated Inverter (String)

Any that is Domestic Content Qualified (Rail + Splice + Fasteners)

Any AVL Approved Module (FEOC Compliant) w/ Greater than 12.1% non-FEOC content

REC

QCells

Silfab

Hyundai

Sirius (by Elin)

Mission Solar

SEG

Who Can Enroll?

All partners are eligible to submit, subject to the below.

What's Required for Enrollment?

1) Example BOM (Bill of Materials) that Installer intends to use

2) Sales Forecast

3) Addendum Signature

Installer Expectations

1) Installer must be in good standing with LightReach, including install approval rates and compliance.

2) LightReach will review requests in the order in which they were received. This process may take a few days. Partners should review status updates on their ticket.

3) Out of fairness to all partners on the platform, LightReach support cannot expedite enrollment requests.

4) Exact ITC-DC pricing values are confidential to installer leadership. PLR will share additional ITC value with installers in the form of a higher EPC payment. Exact values are generally standardized by tier.

How to Enroll

Use the Calculator

DC percentage and qualification of each SKU will be determined by the use of the calculator

Threshold

To be eligible for domestic content pricing, the equipment combination used on the install must meet the 50% domestic content value

Equipment Eligibility

is subject to change. Domestic Content is an evolving topic and will change as time goes on

Calculator How-To Video

Found here
​

ITC-DC Eligible Equipment

Please refer to in-portal calculator for eligibility and percentages.

1) QCells

2) Silfab

3) Elin / Sirius PV

4) Longi

1) Enphase

2) SolarEdge

3) Tesla

1) Enphase

2) SolarEdge

3) Tesla

1) Ecofasten

2) IronRidge

3) K2

4) Pegasus

5) SnapNRack

6) Unirac

1

Is Domestic Content Mandatory?

No, the program is optional

2

My Org is enabled with Direct pay, can we participate in Domestic Content?

Yes

3

How do I Enroll?

Please refer to Section B for more information on how to enroll.

4

If I'm enrolled, but my team sells in an external sales portal, how do I view ITC-DC values?

External sales portals, such as Solo, will display the ITC-DC values (higher values).

Both ITC-DC and standard values are visible in the LightReach portal for convenience.

5

How can I calculate whether my project is eligible for Domestic Content?

Use the in-portal calculator to help guide eligible combinations.

The DC calculator is the source of truth for specific SKUs that qualify

6

Will Domestic Content projects receive conditional approvals?

Domestic Content projects will NOT be conditionally approved at install. Partners will need to either provide sufficient proof OR “opt out” of Domestic Content for the project to proceed with the non-DC boost pricing.

7

What % do I need to achieve to have a project qualify for ITC-DC?

As of January 1st 2026, a 50% domestic content value threshold is required to be met, but installers should bear in mind that this threshold will increase by 5% each year, meaning that on January 1st 2027, the threshold will be 55%.

8

Will Storage selection provide an additional boost on ITC-DC pricing?

PV provides an avenue ITC-DC boost.

PV + Storage provides an avenue to a larger ITC-DC boost.

Storage-Only does not provide an avenue for a boost.

9

Can I use multiple hardware manufacturers/OEMs?

No, mounting hardware with multiple OEMs (Original Equipment Manufacturers) is not permitted.

All racking components used on any given site must be from the same manufacturer.

Case by case flexibility may be provided in the case of Module-Mount MLPE fasteners from other OEMs are necessary. Please contact your relationship manager in advance for potential options.

10

Qualifying for Domestic Content on Mounting Hardware?

To qualify for ITC-DC on mounting hardware, you need:

The Basics

All installers must be FEOC (Foreign Entity of Concern) compliant, and use equipment on our AVL. Installers should simply procure equipment via their normal processes--Using safe harbored equipment in 2026 isn't necessary in the majority of cases.

Who can Safe Harbor for TPO products?

Palmetto LightReach. Individual installers cannot Safe Harbor directly for LightReach sales, due to fine print complexities. For the avoidance of doubt, there are no workarounds to this.

What's the Process Look Like?

For those few select partners participating in Safe Harbored equipment in the short term, the process involves:

What is Palmetto's strategy geared toward?

We are primarily focused on the front of preserving the ITC value, thereby maintaining our competitive pricing.

Shorter term use of Safe Harbored equipment as a Buffer is small in scope, and involves only a few select partners with select equipment bundles.

For the avoidance of doubt, if you have not already directly worked with Palmetto leadership on a specific shorter term safe harbor, we will not be able to make any other special accommodations.

How will Palmetto's Safe Harbored equipment be allocated?

Formal process to be announced in late 2026/Early 2027.

Direct Pay will remain optional, and pricing will not be expressly directed by Palmetto (IE partners will have flexibility to use their existing distributor SPAs as desired).