SECTION 4. POSSIBLE PIN

ASSIGNMENT SYSTEM AND SPECIFIC REQUEST FOR COMMENTS

The Treasury Department and the IRS are considering implementing a PIN assignment system, the process for which

January 29, 2024 620 Bulletin No. 2024–5

is described generally in section 4.01 of this notice. The system would use 17-digit PINs that are assigned to each item of specified property that qualifies for the § 25C credit. The PIN for each item of specified property would be made up of three parts. The first part of the PIN would be a “QM Number” specific to the qualified manufacturer. The second part of the PIN would be a “Product Number” specific to the specified property product line that qualifies for the § 25C credit. The third part of the PIN would reflect the year of manufacture. The fourth part of the PIN would be an “Item number” that is unique to each item of specified property. The system would require manufacturers to register to be a qualified manufacturer with the IRS. Only if registration is successful would any PINs be assigned to the manufacturer’s items of specified property. The Treasury Department and the IRS request comments on the proposed system.

.01 Possible PIN Assignment System Process .

(A) The manufacturer would register with the IRS to be a qualified manufacturer (QM) in accordance with § 25C(h) (3).

(B) If the registration is successful, the manufacturer would become a qualified manufacturer, and the IRS would issue to the qualified manufacturer a QM Number and a list of Product Numbers that correspond to specified products that qualify for the § 25C credit. QM Numbers and Product Numbers would only include alphanumeric characters. For purposes of this notice, “alphanumeric characters” refers only to 24 letters of the English alphabet (A through Z, but not I or O to avoid confusion with 1 and 0) and the numerals 0, 1, 2, 3, 4, 5, 6, 7, 8, and 9. (C) The qualified manufacturer would then assign Item numbers to each unique item of specified property in any fashion it chooses (for example, sequentially, partially incorporating the year and/or month of manufacture, or incorporating a part or all of the serial number that the manufacturer has assigned to the item), provided that the Item numbers only include alphanumeric characters, and provided that the PIN is unique for each item and is 17

alphanumeric characters in overall length (including the QM Number, the Product Number, and the character(s) identifying the year of manufacture).

(D) Throughout the calendar year, the qualified manufacturer would file a list of PINs representing each item of specified property manufactured by the manufacturer to the IRS through an online portal ² before, or potentially shortly after, the end of the calendar year. The qualified manufacturer would stamp or label its products with their PINs, and would also, potentially through a retailer, distributor, or contractor, furnish the PINs to each consumer for the consumers to report on their tax returns when the § 25C credit is claimed. See section 5 of this notice for comment requests on providing PINs to customers and the IRS.

.02 Example . Manufacturer X manufactures exterior windows. On June 1, 2024, Manufacturer X successfully registers with the IRS to be a qualified manufacturer and the IRS assigns a QM Number of 1234 to Manufacturer X. The IRS also provides Manufacturer X a Product Numbers list, in which exterior windows that qualify for the § 25C credit are assigned number 01. Manufacturer X anticipates that, in calendar year 2025, it will manufacture 50,000 exterior windows that will qualify for the § 25C credit and decides to assign numbers to each exterior window sequentially based on the time of manufacture. Accordingly, Manufacturer X assigns PINs of 12340125000000001 through 12340125000050000 to the exterior windows it produces in calendar year 2025. Also in calendar year 2025, Consumer Y purchases and places in service the exterior window bearing the PIN 12340125000000001. Before or potentially shortly after January 1, 2026, Manufacturer X notifies the IRS of this PIN through a report filed through the IRS Energy Credits Online portal. Additionally, Consumer Y has been made aware of the PIN unique to the exterior window purchased by Consumer Y to report on their return.

.03 The Treasury Department and the IRS request comments on the PIN assignment system described in section 4.01

of this notice. Specifically, the Treasury Department and the IRS request comments on the following:

(A) What challenges would manufacturers and/or retailers have in implementing and complying with the PIN assignment system described in section 4.01 of this notice? What would be the costs and timeline for manufacturers and retailers of implementing and complying with the proposed system? Are there cases where manufacturers or other stakeholders would decline to employ the system because compliance would be overly burdensome? Commenters are encouraged to specifically identify types and amounts of costs that manufacturers and retailers would need to incur in implementing and complying with the proposed system, as well as specific aspects of the proposal that would require set amounts of time to develop and implement.

(B) If the Treasury Department and the IRS were to implement the PIN assignment system described in section 4.01 of this notice, what changes or exceptions, if any, should be made? For example, is guidance regarding a transition period needed for specified property that may be placed in service after December 31, 2024, but is no longer in possession of the manufacturer or trackable by the manufacturer on the date they successfully register with the IRS, because the specified property has already been sold to a distributor or retailer? Do some categories of specified property, or components of specified property, have a low retail cost or profit margin such that assigning a PIN to each item would be cost-prohibitive? Please also provide recommendations on any possible demarcation between items or categories of specified property that would need a PIN, or for which a PIN would be impractical, and those that would not need a PIN and the basis for such demarcation consistent with the purposes of the statutory PIN requirement to prevent duplicative or fraudulent credit claims.

(C) If the Treasury Department and the IRS were to implement the PIN assignment system described in section 4.01 of this notice for some items of specified property, but not others, would there be

2 Similar to the IRS Clean Vehicle Credit portal.

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additional costs incurred for manufacturers and/ or retailers? What would those additional costs be?

(D) What challenges, if any, exist due to customizable products? What limitations, if any, does specified property that is sold in one or more parts to form an eligible system (for example, an eligible heat pump system that is comprised of an indoor unit, outdoor unit and air mover) pose in assigning unique PINs?

(E) If the Treasury Department and the IRS were to implement the PIN assignment system described in section 4.01 of this notice, with what frequency (daily, monthly, quarterly, annually) could manufacturers provide information to the IRS, retailers, and/or consumers on available specified property?

(F) What modifications could be made to the PIN assignment system described in section 4.01 of this notice to accommodate limitations while still achieving adherence to the specificity requirement?