SECTION 6. PIN LABELING

REQUIREMENT

.01 In General. To satisfy the PIN labeling requirement in § 25C(h)(3)(B), a QM must label each item of specified property with a PIN using a method allowed in this section 6, and must furnish the PIN to taxpayers in accordance with this section 6.

.02 Method of Labeling . QMs may choose the method for labeling products, provided that the PIN is furnished to the taxpayer in the time frame set forth in section 6.03 of this revenue procedure. For example, a QM may add the PIN to the item of specified property by affixing a label to the product or by etching the PIN on the product itself. Alternatively, a QM may affix a label containing the PIN to the item’s packaging, print the PIN directly on the packaging, or include a document containing the PIN inside the item’s packaging. The IRS urges QMs not to place a product’s PIN on the exterior packaging of the product, which could cause difficulties in the administration of the section 25C credit through misuse of PINs. For property that is no longer in a QM’s control, a QM may provide a website where taxpayers may obtain a PIN by entering their purchase information.

Bulletin No. 2024–46 1117 November 12, 2024

.03 Time to Furnish PINs to Taxpayers; No Prerequisites to Receiving the PIN .

(1) In general . For specified property placed in service on or after January 1, 2025, and before January 1, 2026, in order to comply with the PIN labeling requirement, a QM must provide its QM Code (which will be accepted by the IRS in lieu of a PIN with respect to this period only) to taxpayers who purchase items of specified property by no later than the date– (i) when the taxpayer places the specified property in service, (ii) when the taxpayer requests a PIN from the QM, or (iii) when the manufacturer becomes a QM, whichever is latest. For specified property placed in service on or after January 1, 2026, in order to comply with the PIN labeling requirement, a QM must make its PINs available to the taxpayer no later than the date when the taxpayer either places the specified property in service, or requests a PIN from the QM, whichever is later. For any specified property produced in calendar year 2025 and placed in service on or after January 1, 2026, and to which only a QM Code has been assigned, the QM must make the full 17-digit PIN available to the taxpayer upon request by the taxpayer.

(2) No Prerequisites to Receive a PIN . A QM may not set prerequisites to a taxpayer receiving a PIN that are not required to verify the purchase of the specified property, such as requiring taxpayers to sign up for promotional emails, texts, or other communications from the QM, its related entities, or partners. However, PINs may be provided through the mail, online, through email, or other means of electronic delivery. PINs may be provided in conjunction with a formal registration for a warranty provided that the taxpayer can easily obtain the PIN without completing the formal warranty registration.

.04 Enabling Property . For enabling property, regardless of whether the enabling property is placed in service after December 31, 2025, the § 25C(h) (3)(B) PIN labeling requirement is met if the QM furnishes its QM Code to taxpayers who purchase items of enabling property. Nothing in section 6.04 of this revenue procedure negates the need for a taxpayer to provide the PIN of the

enabled property on the taxpayer’s tax return.

.05 PIN Labeling for Heat Pumps . Because only the outdoor unit of a heat pump that meets the requirements of § 25C(d)(2)(ii) must be assigned a PIN, manufacturers are not required to label the indoor unit of a heat pump. Nothing in section 6.05 of this revenue procedure negates the need for a manufacturer to register to be a QM under section 4 of this revenue procedure, even if the manufacturer only produces indoor units of a heat pump, despite modified requirements applicable to those QMs elsewhere in this revenue procedure.