AVL & All Things Hardware

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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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FEOC Compliant ✅

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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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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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Canadian #1

CS1Y

CS1Y-xxxMS

Leaving AVL 1/1/26

390-405

Canadian #2

CS3N

CS3N-xxxMS

Leaving AVL 1/1/26

380-405

Canadian #3

CS6.1-54TM

CS6.1-54TM-xxxH

Leaving AVL 1/1/26

435-470

Canadian #4

CS6.2-48TM

CS6.2-48TM-xxxH

Leaving AVL 1/1/26

440-470

Canadian #5

CS6R MS

CS6R-xxxMS

Leaving AVL 1/1/26

380-420

Canadian #6

CS6R MS

CS6R-xxxMS-HL

Leaving AVL 1/1/26

380-405

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JA #1

JAM54D41

JAM54D41-xxx/MB

Leaving AVL 1/1/26

415-440

JA #2

JAM54S31

JAM54S31-xxx/MR

Leaving AVL 1/1/26

380-405

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Jinko #1

JKM - Eagle 66TR G4

JKMxxxM-6RL3-B

Leaving AVL 1/1/26

380-400

Jinko #2

JKM - Eagle Continental

JKMxxxM-72HBL-V

Leaving AVL 1/1/26

380-400

Jinko #3

Eagle 54 G6R

JKMxxxN-54HL4-B

Leaving AVL 1/1/26

420-440

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Longi #1

Hi-MO 5

LR5-54HABB-xxxM

Leaving AVL 1/1/26

390-415

Longi #2

Hi-MO 5

LR5-54HPB-xxxM

Leaving AVL 1/1/26

400-420

Longi #3

Hi-MO 5

LR5-54HPB-xxx - Domestic

Leaving AVL 1/1/26

390-410

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Maxeon 1

SPR-MAX3-BLK

SPR-MAX3-xxx-BLK-R

Leaving AVL 1/1/26

405-420

Maxeon 2

SPR-MAX3

SPR-MAX3-xxx-R

Leaving AVL 1/1/26

415-430

Maxeon 3

SPR-MAX6

SPR-MAX6-xxx

Leaving AVL 1/1/26

425-440

Maxeon 4

SPR-MAX6-BLK

SPR-MAX6-xxx-BLK

Leaving AVL 1/1/26

410-425

Maxeon 5*

SPR-X21

SPR-X21-xxx-BLK

*Refer to Section A

Leaving AVL 1/1/26

350-350

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Trina #1

Vertex S

TSM-xxxDE09

Leaving AVL 1/1/26

380-405

Trina #2

Vertex S

TSM-xxxDE09C.07

Leaving AVL 1/1/26

380-405

Trina #3

Vertex S+

TSM-xxxNE09RC.05

Leaving AVL 1/1/26

410-435

Trina #4

Vertex S+

TSM-xxxNE09RC.05

Leaving AVL 1/1/26

380-405

Trina #5

Vertex S+

TSM-xxxNE09RH.05

Leaving AVL 1/1/26

420-445

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VSUN #1

108BMH

VSUNxxx-108BMH

Leaving AVL 1/1/26

390-405

VSUN #2

120BMH

VSUNxxx-120BMH

Leaving AVL 1/1/26

355-370

VSUN #3

132BMH

VSUNxxx-132BMH

Leaving AVL 1/1/26

400-415

VSUN #4

108BMH-BB

VSUNxxxN-108BMH-BB

Leaving AVL 1/1/26

415-440

Add'l Details

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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EnpBat #1

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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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.

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

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). Put plainly: At least 40% for PV and 55% for Battery of installed equipment cannot come from a Foreign Entity of Concern. Palmetto will execute calculations for our partners (in-portal calculator coming soon).

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

Put plainly: 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.

FEOC Example

An installation using an MLPE Inverter (SE, Enphase, QCell).

40% FEOC Compliance can be achieved via:

[Option A]

[Option B]

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

Latest Update to this Article

12/12/25

Next Est. FEOC Update

12/15/25

Partners are advised to begin navigating away from large purchases of Chinese-owned modules such as Trina, Jinko, JA, Longi, and Canadian Solar.

Projects with these 2025 modules must have M1 install packages submitted by 12/31/25 to qualify.

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 45% 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 the latest federal update in June 2025, a 45% 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 2026, the threshold will be 50%.

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:

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.

How does Palmetto Safe Harbor?

We work directly with OEMs (manufacturers) and Distributors, along with our tax partner, Deloitte.

What is Palmetto's strategy geared toward?

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

Palmetto is planning some smaller, shorter-term Safe Harbor purchases for non-FEOC-compliant equipment; however, quantities and scope will be limited.

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.

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).

How much equipment will be available?

Via Safe Harbor and Supply Agreements, we will be able to support FEOC compliance for all sales as forecast with you, our partners. This will ensure that all partners have FEOC-compliant equipment in 2026.

However, it should be noted that Domestic Content panels are likely to be in shorter supply, especially in Q1 2026.