Domestic Content
The inflation reduction act’s domestic content bonus is an important tool for investing in american workers and american businesses. Projects that meet the domestic content requirement receive up to a 10-percentage point bonus on top of the 30% ptc or itc. 1
Proudly made in the USA
PanelClaw has a long history of supporting American businesses. We have always produced the large majority of our racking system components in the U.S. using U.S. sourced raw materials. Unlike many other solar industry suppliers, PanelClaw does not have to completely rebuild its supply chain to unlock this attractive incentive for its customers. As a result, PanelClaw customers need not worry about impacts to manufacturing capacity, lead times or pricing.
PanelClaw’s clawFR and clawFRplus mounting systems are manufactured in the U.S.A. We have over 15 years of experience manufacturing flat roof products in the US with an annual capacity of 1.5 GW.
Since the IRA was signed into law in 2022, the Department of Treasury and the Internal Revenue Service have issued guidance for determining domestic content bonus credit amounts on three occasions. The most recent update was released in January 2025 – continue reading for more details.
Updated Guidance on Domestic Content
On January 16, the U.S. Department of the Treasury (Treasury) and the IRS issued updated guidance on the Inflation Reduction Act’s domestic content bonus for Clean Electricity Production and Investment Tax Credits. Notice 2025-08 builds on the domestic content safe harbor table released in May 2024 (Notice 2024-41), allowing developers to use Department of Energy cost percentages instead of supplier data to qualify for the bonus. Both Notices build from the original “Domestic Content Bonus Credit Guidance under Sections 45, 45Y, 48, and 48E” released in May 2023 (Notice 2023-38).
The revised Safe Harbor Table impacts module, inverter, and racking system manufacturers, affecting how developers plan projects. This guidance is effective immediately and remains valid unless superseded, with a 90-day transition period after any future updates. The May 2024 Safe Harbor Table is still usable for taxpayers provided their projects commence before April 16, 2025. This means customers must either physically start the project or procure 5% of the project materials by this deadline. Developers can also opt for the Direct Cost Method from Notice 2023-38.
Highlights from Updated Safe Harbor Table for Rooftop Solar
- In prior guidance, it was possible to clear the domestic content hurdle of 40% (expected increase to 45% and beyond) without requiring US-made modules containing US-made PV Cells. The Biden Administration’s policy aggressively incentivized the re-shoring of PV cell and PV module manufacturing to the US; and the latest Notice effectively ensures the paths to clearing the domestic content hurdle – with only one exception for MLPE+racking – must include a contribution from a US-manufactured PV module.
- Incentives for the re-shoring of silicon wafer manufacturing to the US are clear in Notice 2025-08. Note the safe harbor table now outlines four different cost percentage allocation scenarios specific to rooftop solar installations. Previous guidance offered only “rooftop-MLPE” and “rooftop-String” scenarios, whereas each of these two scenarios in the new Notice are split into two, depending upon whether PV modules include domestic wafers.
Manufacturers and developers must analyze these changes, considering component availability, costs, and future domestic manufacturing trends.
What’s Next?
We are committed to providing the support and documentation required to monetize this credit and any others that involve our racking. For those that want to leverage the credit using the latest IRS guidance or the previous guidance, please contact your sales representative for more information.
PanelClaw does not provide tax, legal or accounting advice. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors before engaging in any transaction.
- the project has a maximum net output of less than 1 megawatt -or-
- the project satisfies the prevailing wage and apprenticeship requirements
Otherwise, projects with domestic content receive a 2% bonus.
