SECTION 5. SPECIFIC REQUEST FOR

COMMENTS ON PROVIDING PINs TO CONSUMERS AND THE IRS

If a PIN assignment system substantially similar to the one described in section 4 of this notice is developed, the Treasury Department and the IRS request comments on how manufacturers (and/or other parties) would provide each unique PIN to consumers and to the IRS to ensure appropriate matching to avoid duplicate or fraudulent credit claims. Specifically, the Treasury Department and the IRS request comments on:

.01 What processes or systems could manufacturers, retailers, distributors, contractors, and/or trade organizations put in place to ensure that consumers can confirm whether a particular item of specified property qualifies for a § 25C credit? For example, could manufacturers, retailers, distributors, contractors, and/ or trade organizations provide a certification to consumers listing which of the manufacturers’ products qualify for the § 25C credit? How could manufacturers, retailers, distributors, contractors, and/or trade organizations make eligible property easily identifiable for consumers? Would manufacturers and/or retailers prefer to provide PIN information to consumers on

receipts at the time of sale or after installation of the product (if different in time)? Would a system where the PIN is provided on or inside the product’s packaging and not on the product itself suffice in certain situations? Could manufacturers and/or retailers provide information on the credit limitations to customers (for example, that the § 25C credit for any eligible single exterior door cannot exceed $250 for any taxable year under § 25C(b)(4)(A))? How does the use of contractors or subcontractors (such as installers) help or limit the ability of manufacturers and/or retailers to put into place any processes or systems relating to the PIN requirement, and if so, please describe?

.02 What processes or systems could manufacturers and/or retailers put into place that would both comply with the labeling requirement under § 25C(h)(3) (B) and adhere to § 25C(h)’s aim to prevent duplicate or fraudulent claims for the § 25C credit for the same unique item of specified property? Could manufacturers and/or retailers employ their own labeling system(s) to provide both the relevant PIN and other relevant information relating to the § 25C credit? Would a receipt be sufficient to meet the labeling requirement? How burdensome would it be to place a physical label on each unique item of specified property containing the relevant PIN and other relevant information relating to the § 25C credit, and would it be less burdensome for manufacturers to place this type of label on certain categories of property than for other categories of property? Would manufacturers and/or retailers provide an information sheet to consumers with each product purchased by the consumer and listing the PIN that applies to each product? What systems and processes could manufacturers and/ or retailers and contractors employ that would help ensure that the PIN is only made available to the consumer who purchases that item?

.03 What processes or systems could manufacturers put into place to ensure that the IRS has the appropriate list of PINs for each unique item of specified property that have been placed in service beginning in 2025? Are there any limitations to manufacturers uploading PIN information to an online portal, such as IRS Energy Credits Online?