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The Solar Energy Manufacturers for America (SEMA) Coalition strongly supports President Trump’s objective of ensuring U.S. energy dominance, including by increasing domestic energy production and ushering in a golden age of American manufacturing of energy-related products and components. This is particularly critical to maximize economic growth and compete with China. At a time of growing domestic energy demand, including from AI data centers that are critical to national and economic security, the United States needs all the energy it can get, and to make as much of it here at home as possible.
The SEMA Coalition is a diverse group of solar manufacturers employing over 14,500 workers united to rebuild the domestic solar supply chain. We represent the interests of the major non-Chinese solar manufacturers who are building or looking to build strategic solar components across the value chain in the U.S. Our coalition advocates for a suite of policies to build a secure and competitive U.S. solar supply chain to meet our current and future energy demand while creating good-paying manufacturing jobs and protecting our national security.
OBBB made significant changes to the U.S. tax code. However, it retained modified versions of the critical tax credits that support domestic advanced energy manufacturing: the Section 45X Advanced Manufacturing Production Tax Credit and the Section 48E Electricity Investment Tax Credit, which includes a Domestic Content adder for projects deployed with increasing thresholds of American-made components. The Section 45X manufacturing credit is the foundation for re-shoring the solar supply chain and has already changed the face of the U.S. solar manufacturing industry. The Domestic Content adder of the Section 48E investment credit serves as a clear demand signal in the market for American-made products built with components produced in America, spurring new investments in domestic advanced energy manufacturing. The changes made to these credits by OBBB have the power to unleash advanced American solar energy manufacturing and combat China’s national security threat to this critical technology and the American energy grid. The new facility-level restrictions on supply chain sourcing from specified foreign entities and foreign influenced entities that exceed specified thresholds (“material assistance”)—where qualified facilities that begin construction after December 31, 2025 cannot include material assistance—are also a welcome change.
In service of that shared objective, the SEMA Coalition offers these comments as Treasury evaluates potential new and revised guidance to implement OBBB—including, in particular, initial guidance directed by EO 14315 regarding the appropriate standards for evaluating when a project has begun construction and the implementation of prohibited foreign entity (also known as “foreign entity of concern” or “FEOC”) restrictions.
