SECTION 4. CLARIFICATION ON

APPLICATION OF TABLES

A taxpayer may elect to use the classifications and cost percentages in Table 1 of Notice 2024-41 or the First Updated Elective Safe Harbor (as applicable) to qualify for the domestic content bonus credit amount for Applicable Projects of the specific types identified in Table 1 or the First Updated Elective Safe Harbor that are eligible for a credit under sections 45, 45Y, 48, or 48E by virtue of the 80/20 Rule. For example, as provided for in Notice 2023-38, an Applicable Project that is eligible for a credit under sections 45, 45Y, 48, or 48E by virtue of the 80/20 Rule is eligible for a domestic content bonus credit amount if the new property in the Applicable Project meets the Domestic Con

tent Requirement and the taxpayer complies with the requirements described in the notice. To determine the Domestic Cost Percentage for such an Applicable Project, the taxpayer may use the classifications and cost percentages in Table 1 or the First Updated Elective Safe Harbor (as applicable). Only new U.S. Manufactured Products and U.S. Components of the Applicable Project that are listed in Table 1 of Notice 2024-41 or of this First Updated Elective Safe Harbor (as applicable) would be considered in the calculation of the Domestic Cost Percentage (with no changes to those tables’ percentages). All other Manufactured Products or Manufactured Product Components, including the used property in an Applicable Project that qualifies as originally placed in service by virtue of the 80/20 Rule, will be treated as foreign-sourced Manufactured Products or Manufactured Product Components solely for purposes of calculating the Domestic Cost Percentage when applying the New Elective Safe Harbor in Notice 202441, and for applying the First Updated Elective Safe Harbor in this notice, and must take a zero value consistent with section 4.03(3) in Notice 2024-41 and section 8.03(3) of this notice. In such cases, new property may be considered in the calculation of the Domestic Content Percentage if it meets the definition of a U.S. Manufactured Product (as defined in section 3.03(1) of Notice 2023-38, including being produced in the United States), or a U.S. Component (as defined in section 3.03(2)(b) in Notice 2023-38, including being mined, produced, or manufactured in the United States). Furthermore, to meet the Domestic Content Requirement, such Applicable Projects must also satisfy the Steel or Iron Requirement with respect to only new Applicable Project Components that are specified as subject to the Steel or Iron Requirement in Table 1 of Notice 2024-41 or this First Updated Elective Safe Harbor (as applicable).

The modification to Notice 2024-41 described in this section does not extend a taxpayer’s ability to rely on Notice 2024-41, as described in section 11 of this notice.

February 18, 2025 802 Bulletin No. 2025–8

ule containing c-Si PV cells made from domestically produced c-Si wafers. The Updated Assigned Cost Percentages for PV Solar are from DOE’s Quarterly Solar Industry Update (publication pending), which are derived from a DOE-led effort that uses data collected from national laboratories.

The Treasury Department and the IRS, in consultation with DOE, implemented the updates described after review of the comments received in response to the request for comments made in Notice 2024-41, which highlighted the expected cost premium incurred from procuring domestically produced c-Si PV cells made with domestically produced silicon wafers. Based on this review and consultation with DOE, the Treasury Department and the IRS concluded that, due to the expected cost premium associated with domestically produced silicon wafers, Table 1 could misrepresent the expected costs of domestically produced c-Si PV cells made with these wafers, thereby reducing Table 1’s accuracy. This inaccuracy could risk under-crediting a component whose value is, to a significant extent, created domestically, while over-crediting other components within the table.

Given these considerations, the Treasury Department and the IRS, in consultation with DOE, have determined that it is appropriate to provide taxpayers the option of using a cost safe harbor that more specifically reflects the cost of c-Si PV cells produced with domestically produced wafers.

.03 Renaming of Certain Components . The First Updated Elective Safe Harbor further modifies Table 1 for Solar PV in section 4.04(1) of Notice 2024-41 by renaming the following Applicable Proj

ect Components and Manufactured Product Components. With respect Applicable Project Components: (i) “Pile or ground screw” is renamed “Steel pile or steel ground screw” for consistency with the description of other items categorized as a steel/iron product, and (ii) “Steel or iron rebar in foundation” is renamed “Steel or iron reinforcing products in foundation” to better reflect its function and to clarify that non-rebar steel or iron reinforcement is also covered.

With respect to Manufactured Product Components: (i) “Climate Control” is renamed “Thermal Management System”; (ii) “Enclosure” is renamed “Enclosure & Skids” for the Inverter Applicable Project Component of both types of groundmount photovoltaic systems; (iii) “Fasteners” is renamed “Structural Fasteners”; (iv) “Slew Drive” is renamed “Drive System”; and (v) “Motor” is renamed “Actuator” to better reflect each Manufactured Product Component’s function by providing specificity.

.04 Redefining, Recategorizing, and Reclassifying Certain Components . The following changes were made after consultation with DOE and review of stakeholder feedback: First, the First Updated Elective Safe Harbor revises the definition of: (i) “Ground-mounted PV (fixed-tilt)” to clarify that it includes canopy steel racking structures and structures floating on a body of water; (ii) “Ground-mounted PV (tracker)” to clarify that it includes structures floating on a body of water; and (iii) “Rooftop PV (MLPE)” to clarify that it refers to a system where the microinverters or DC-optimizers regulate the DC electricity from each of its solar PV modules independently before the electricity is converted into alternating current electricity.

Second, the First Updated Elective Safe Harbor clarifies that the Manufactured Product Component “Electrical Parts” for ground-mount PV systems includes the following components that are not on printed circuit board (PCB) assemblies: control transformers, capacitors, inductors, bus/cables, circuit protection.

Third, as provided in the table in section 5.06 of this notice, the First Updated Elective Safe Harbor removes “Electrical Parts for rooftop PV systems,” and adds their costs to “Printed Circuit Board Assemblies” (DC-DC) and “Printed Circuit Board Assemblies” (DC-AC). ⁴

Fourth, for “Solar PV Rooftop”, the First Updated Elective Safe Harbor categorizes DC-to-DC and DC-to-AC “Printed Circuit Board Assemblies” as separate Manufactured Products Components, and the domestic “Printed Circuit Board Assemblies” that perform both functions (that is, convert both DC to DC and DC to AC) can get credit for each cost percentage. ⁵

Fifth, “Adhesives,” which is listed as a Manufactured Product Component for PV Solar in Table 1, is removed from the First Updated Elective Safe Harbor to avoid redundancy and confusion because “Pottants” and “Edge Seals,” which are listed as Manufactured Product Components within the First Updated Elected Safe Harbor, are also adhesives. As such, to reflect the removal of “Adhesives” within the Updated Assigned Cost Percentages for PV Solar, the Treasury Department and the IRS, in consultation with DOE, increased the associated cost percentage for both “Pottants” and “Edge Seals”. See tables in section 5.05 and 5.06 of this notice.

.05 Updated Table for Solar PV Ground-Mount

4 The abbreviated terms “DC” and “AC” are generally industry accepted terms meaning “Direct Current” and “Alternating Current,” respectively.

5 Larger inverters, such as those in most ground-mount applications, have fundamentally different architectures than smaller inverters. As such, DOE assessed that a similar change would not improve the accuracy of the cost percentages for ground-mount PV systems.

Bulletin No. 2025–8 803 February 18, 2025

6 Although “Production” is listed under the column for Manufactured Product Components (MPCs), it is not an MPC. “Production” refers to the production cost of the relevant Applicable Project Component (APC) that is a Manufactured Product and can only be included in the Domestic Cost Percentage if all of the Manufactured Product Components of that Manufactured Product APC are domestically produced. See section 3.03(2) of Notice 2023-38.

7 Consistent with Notice 2023-38, the direct cost of producing a Manufactured Product counts toward the Domestic Cost Percentage only if all its Manufactured Product Components are domestically produced.

February 18, 2025 804 Bulletin No. 2025–8

.06 Updated Table for Solar PV Rooftop

.07 Definitions . (1) Actuator. Actuator means the component that produces the force, torque, and displacement.

(2) Backrail . Backrail means the component that secures the module laminate to its support structure. A Backrail can be used for the same purposes and in place of a Frame .

(3) Backsheet/Backglass . Backsheet/ Backglass means the sheet or piece of glass on the back of solar modules that acts as an electric insulator and protects the inner components of such module from the surrounding environment.

(4) Cells. Cells in a PV module means the smallest semiconductor element of a

solar module which performs the immediate conversion of light into electricity.

(5) Controller. Controller means the component that transmits operating instructions to the actuator.

(6) Crystalline silicon cells. Crystal- line silicon cells, also referred to as c-Si cells, means a cell in a PV module, as defined in section 5.05(4) of this notice, that is made of silicon atoms connected to form a lattice.

(7) Drive system. Drive system means the components that transmit force, torque, or displacement from the actuator to the torque tube.

(8) Electrical parts. Electrical parts mean the components consisting of only

control transformers, capacitors, inductors, bus/cables, and circuit protection not on printed circuit board (PCB) assemblies.

(9) Encapsulant. Encapsulant means the material used to adhere the cell strings between the front and rear glass (or backsheet) for the purpose of protecting against environmental stress.

(10) Enclosure: Enclosure means the protective structure that houses, that is, encloses, the other inverter components.

(11) Frame. Frame means the component that secures the module laminate to its support structure.

(12) Front glass : Front glass means the transparent, protective, structural front layer of a PV module.

8 Consistent with Notice 2023-38, the direct cost of producing a Manufactured Product counts toward the Domestic Cost Percentage only if all its Manufactured Product Components are domestically produced.

9 For purposes of this table, module-level power electronics inverter systems, including either microinverters or direct current (DC) optimizers, are considered an inverter product.

10 In instances in which a U.S. Component meets the criteria of more than one listed manufactured product component, it can claim all relevant Updated Assigned Cost Percentages.

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(13) Ground-mounted PV (fixed-tilt) . Ground-mount PV (fixed-tilt) refers to an energy system using photovoltaic solar modules to generate electricity, mounted to a non-building structure, including canopy steel racking structures, or floating on a body of water, where the PV modules are mounted at a fixed angle and orientation.

(14) Ground-mounted PV (tracker) . Ground-mount PV (tracker) refers to an energy system using photovoltaic solar modules to generate electricity, mounted to a non-building structure, or floating on a body of water, which integrates a solar tracker to rotate the solar modules.

(15) Junction box . Junction box means the component that connects PV cell strings and keeps power flowing in one direction.

(16) Printed circuit board assemblies. Printed circuit board assemblies means finished, fully functional printed circuit boards that have all necessary subcomponents soldered and installed on to them.

(17) Rails. Rails, including the components known as purlins, means the components that attach modules to torque tubes.

(18) Rooftop PV (MLPE) . Rooftop PV (MLPE) refers to an energy system using photovoltaic solar modules to generate electricity, mounted to a building structure, which integrates one or more microinverters or uses a DC-optimized inverter system such that the rooftop PV system (with its microinverter(s) or DC-optimized inverter system) regulates the DC electricity from each of its modules independently before that

electricity is converted into alternating current electricity.

(19) Rooftop PV (string inverter) . Rooftop PV (string inverter) refers to an energy system using photovoltaic solar modules to generate electricity, mounted to a building structure, which integrates one or more inverters to convert direct current electricity from a string of solar panels into alternating current electricity.

(20) Skid. Skid means that component upon which the enclosure sits.

(21) Structural Fasteners. Structural Fasteners for use in ground-mount PV applications means a component that is used to connect the mechanical and drive system components of a solar tracker to the foundation of the solar tracker, to connect torque tubes to drive assemblies, or to connect segments of torque tubes to one another. Structural Fasteners for use in rooftop PV applications means a component that connects the rails, modules, and MLPE (if applicable) to one another.

(22) Thermal management system. Ther- mal management system means the system consisting of the heat sinks, heat pipes, fans and/or the liquid cooling systems.

(23) Torque tubes. For purposes of the Manufactured Product Components provided within the table under section 5.05 of this notice, Torque tubes means a structural support element, including longitudinal purlins that: (i) is part of a solar tracker; (ii) is of any cross-sectional shape; (iii) may be assembled from individually manufactured segments; (iv) spans longitudinally between foundation

posts; (v) supports solar panels and is connected to a mounting attachment for solar panels (with or without separate module interface rails); (vi) and is rotated by means of a drive system.

(24) Wafer . Wafer means a thin slice, sheet or layer of crystalline silicon semiconductor material that comprises the substrate or absorber layer of one or more photovoltaic cells. It is manufactured by forming an ingot from molten polysilicon and then slicing it into wafers, or by depositing a thinfilm semiconductor photon absorber into a sheet or layer, that is, a thin-film deposition.