FEOC Regulations Spark MASSIVE Supply Chain Disruptions

The global supply chain for batteries and solar equipment faces unprecedented complexity in 2025. If you're a developer or asset owner planning projects for 2026 and beyond, this conversation is essential listening.
Christian Roselund, Senior Policy Analyst at Clean Energy Associates, breaks down the intricate web of rules, tariffs, and supply chain constraints affecting the clean energy industry. With 80% of battery cells used in the United States coming from Chinese manufacturers, developers face a critical challenge: how to source equipment while maintaining access to the Investment Tax Credit (ITC).
In this episode, we explore the material assistance cost ratio, effective control provisions, and the practical implications of restrictions on both solar and battery projects. Christian explains why battery supply presents an even greater challenge than solar, with insufficient US cell manufacturing capacity to meet US market demand through at least 2028.
We discuss strategies developers are using to navigate these restrictions, including construction timeline optimization, blending approaches, and the shift toward Korean and European battery suppliers. Christian also addresses the compounding impact of Section 301 tariffs, IEEPA tariffs, and the Uyghur Forced Labor Prevention Act (UFLPA) on supply chain decisions.
Key topics covered:
- Material assistance cost ratios for ITC and PTC eligibility
- Construction start date strategies to lock in tax credits
- Current US battery cell manufacturing capacity vs. demand
- Geographic sourcing alternatives for batteries and solar cells
- Tariff impacts on equipment costs from China and other regions
- UFLPA compliance and traceability requirements
- Why battery storage faces longer-term challenges than solar
Whether you're developing utility-scale projects or managing procurement for an asset owner, understanding these supply chain dynamics will determine your ability to deliver cost-effective projects while maintaining tax credit eligibility.
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