Meeting the Moment: The Compliance Challenge Shaping Clean Energy

Realizse Insight Series, Issue 3 of 7

The New Reality: Clean Energy Supply Chains Under the Microscope

The clean energy boom is built on equipment and components—panels, batteries, inverters, steel, wire, and everything in between. But now, under the One Big Beautiful Bill (OB3), these supply chains are coming under unprecedented scrutiny.

The OB3, reinforced by the July 7, 2025 Executive Order, extends federal-level compliance and documentation standards across every entity touching a tax credit-eligible renewable energy project—including OEMs and material suppliers.

If you manufacture or distribute any product used in IRA-linked projects, you are now expected to provide traceable, auditable, and tamper-proof documentation proving that your products meet origin, labor, and sourcing standards. Failure to do so could make the project—and your customer—ineligible.

The Core Risk: FEOC Compliance

At the center of the storm is the Foreign Entity of Concern (FEOC) rule, a national security safeguard buried within the IRA and recently prioritized by IRS and DOE. OB3 brings it to the forefront.

Any tax credit-eligible project that uses components linked to a FEOC—even indirectly—can be disqualified. That includes:

• Solar panels

• Wind turbines

• Battery cells and packs

• Inverters and charge controllers

• Switchgear, cabling, and more

Where OEMs Are Exposed

This isn't theoretical. Multiple buyers are now requiring suppliers to provide digital traceability to ensure safe harbor qualification—and insurers are following suit.

What OB3 Demands from OEMs

The federal compliance expectations for suppliers and OEMs now mirror what has long been expected in sectors like aerospace and defense:

• Digital proof of country of origin

• Documentation of labor conditions across the value chain

• Product-level digital identity anchored to the asset

• Full audit trails from raw material to project site

• Integration into buyer or developer compliance platforms

The Pain Point: Most OEMs Aren’t Ready

Today, most OEMs rely on internal procurement systems and PDF-based certifications, which cannot prove compliance under OB3 audit scrutiny. Most have no tamper-proof data trail, no integration with downstream developers, and no standardized method to validate origin.

That’s the blind spot. And it’s now a risk—for you and your customers.

What Suppliers Must Do Now

To remain IRA-eligible and keep customers in the green:

• Digitize product-level compliance data

  • Origin, sourcing, labor, ESG, warranty

• Issue Digital Product Passports (DPPs)

  • Immutable, machine-readable records

• Integrate with project-level compliance platforms

  • Ensure data flows to tax credit buyers and underwriters

• Structure documentation to survive 6–10 years of audits

  • Not just for today, but for resale, insurance, and secondary markets

It’s Not Just Compliance—It’s a Competitive Advantage

OEMs who provide digital, audit-ready product records will be favored by:

• Developers seeking safe harbor validation

• Buyers trying to reduce tax credit risk

• Insurers offering performance guarantees

• Financiers backing bankable deals

By offering traceable, validated, compliant components, you don’t just mitigate risk—you become essential

Bottom Line: Build Trust or Be Left Behind

In the post-OB3 world, product traceability is the new ESG—not a talking point, but a requirement. If you can’t prove origin, fair labor, and compliance in a standardized, digital format, you risk exclusion from the IRA incentive supply chain.

For OEMs, that’s not just a legal risk. It’s a lost market.

Coming Next

Issue 4 of 7: Investors & the Due Diligence Dilemma – How OB3 Changes the Risk Profile of Every IRA-Linked Project

About Realizse:

Realizse delivers the trusted compliance and product traceability infrastructure clean energy finance now demands. Our flagship solution, the Realizse Passport, transforms fragmented, unverifiable records into a unified, tamper-proof, cryptographically verifiable system of record trusted by all stakeholders.

By providing audit-ready compliance and product traceability data, Realizse unlocks liquidity, mitigates recapture risk, lowers insurance premiums, and reduces audit cost and response time — enabling faster financing and stronger ROI across the clean energy lifecycle.