OBBBA’s FEOC thresholds apply equally to land-based and offshore wind. Yet wind’s hardware – towers, nacelles, blades, and rare-earth magnets – spans dozens of suppliers across multiple continents. U.S. DOE’s Wind Supply-Chain Deep Dive flags several structural risks: declining U.S. blade factories, dependence on imported large steel castings, and over 70% of rare-earth production and nearly all magnet manufacturing being concentrated in China.1
With FEOC rules kicking in for tax years after July 4 2025, projects that don’t document non-FEOC content risk losing 45Y/48E eligibility and – by extension – tax-equity appetite.
What Teams Need to Track for FEOC Compliance
Based on the DOE Wind Energy Supply Chain Deep Dive Assessment (Treasury compliance still pending), we’ve outlined key supply chain components that may be required for diligence under the new FEOC guidelines:
Where BuildQ Fits In
- Single Source of Truth – BuildQ’s diligence tracker keeps every contract, certificate, and supplier affidavit in one organized workspace, so teams aren’t hunting through email chains when FEOC questions arise.
- Component-level Organization – Link turbine purchase orders with nacelle casting certificates, magnet origin documents, and vessel charter contracts in one place.
- Audit-Ready Version Control – Each document’s revision history lives alongside the financial model and IC memo, giving investors a clear lineage of “who changed what, when” if compliance ever comes under review.
- Visibility Across Functions – Project finance, sourcing, and legal teams share the same live dashboard, reducing last-minute scrambles and ensuring everyone works from the latest data.
Why It Matters
- Schedule Protection – Non-compliant components discovered late can push COD past the 2027 phase-down cliff.
- Cost Discipline – Avoid premium “panic purchases” by visualizing supply gaps early.
- Policy Resilience – A verified, domestic-leaning supply chain reduces exposure to tariff shocks and future legislative swings.
Key Dates & Next Steps
- Q3 2025 – Vessel charters signed after this date must pass the FEOC test if the project starts construction in 2026.
- 2027 COD cliff – Projects sliding past 12/31/2027 lose the 45Y/48E credit unless the FEOC ledger is locked and compliant.
