Treasury Notice 2026‑15, issued on February 12, 2026, clarified the application of the One Big Beautiful Bill Act’s foreign entity of concern rules. T1 Energy announced on February 17 that the notice’s safe‑harbor provisions and material‑assistance‑cost‑ratio methodology confirm the company’s domestic supply chain—polysilicon from Hemlock Semiconductor, wafers from Corning, and steel frames from Nextpower—meets the Treasury’s material‑assistance and ownership criteria for Section 45X production tax credits.
The notice establishes a safe‑harbor threshold of a 30‑percent material‑assistance‑cost‑ratio and provides a clear calculation method. Under these rules, T1’s supply‑chain partners are fully U.S.‑owned or non‑foreign‑entity‑of‑concern, and the company’s own manufacturing footprint satisfies the ownership requirement, thereby removing the primary regulatory hurdle that could have disqualified it from the credit program.
Securing eligibility for the 45X credit gives T1 a per‑unit subsidy that underpins its strategy to build the first end‑to‑end U.S. solar supply chain. The credit is expected to lift the company’s gross margin by roughly 1.5 percentage points, supporting the projected cash‑flow inflection in Q4 2025 and reinforcing investor confidence in its policy‑driven moat.
Dan Barcelo, chairman and CEO, said, “T1 is an American‑owned and controlled company committed to investing in advanced American manufacturing, building a domestic and non‑FEOC solar supply chain, and bringing solar technology and know‑how back to America.” He added, “G2_Austin is a centerpiece of our strategy to build an integrated U.S. polysilicon solar supply chain, and we’re pleased Treaty Oak shares our belief in the value of American modules.”
The guidance comes after the One Big Beautiful Bill Act was signed into law on July 4, 2025, and follows the Inflation Reduction Act’s Section 45X incentives. By aligning with the new FEOC rules, T1 positions itself to capture the full benefit of the credit, potentially accelerating its move toward a self‑sustaining domestic manufacturing ecosystem.
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