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Industrial policy

IRA FEOC cleanliness checker.

Eight yes, no, and unknown questions on a vehicle battery supply chain. The tool maps answers to a Section 30D consumer credit eligibility verdict against the Foreign Entity of Concern rules. All evaluation runs locally; nothing is sent to a server.

Indicative only, not legal advice. Verdicts here do not constitute a written opinion under 26 CFR 1.30D-6 and do not bind Treasury or the IRS. Consult counsel before relying on any conclusion for compliance.

Questions

Q1. Is any cell, module, or pack manufactured by a Foreign Entity of Concern?
Q2. Is more than 25 percent of cathode active material extracted, processed, or recycled by a FEOC?
Q3. Is more than 25 percent of anode active material extracted, processed, or recycled by a FEOC?
Q4. Is the separator (including binder and additives) extracted, processed, or recycled by a FEOC above the de minimis threshold?
Q5. Is the electrolyte (salt and solvents) extracted, processed, or recycled by a FEOC above the de minimis threshold?
Q6. Critical minerals: is lithium (carbonate, hydroxide, or metal) sourced from a FEOC?
Q7. Critical minerals: is graphite (natural or synthetic, anode-grade) sourced from a FEOC?
Q8. Critical minerals: is NdPr or another rare earth element (for permanent magnets in the drive unit) sourced from a FEOC?

Verdict

Section 30D status
Likely 30D-eligible (consumer credit retained)

All eight checks return No. On these facts, the vehicle would not be disqualified by the cell-component or critical-minerals FEOC rules. Verify with first-tier supplier attestations and a chain-of-custody audit before placing in service.

Decision logic

  • Any of Q1, Q2, Q3, Q4, Q5 = Yes -> 30D-disqualified (cell-component rule)
  • Any of Q6, Q7, Q8 = Yes -> critical-minerals risk, requires further analysis
  • Any Unknown -> verdict held; supplier attestation required
  • All eight = No -> likely 30D-eligible

Citation: Treasury Final Rule, 26 CFR Part 1.30D-6, May 2024 (modified through Q1 2026). See also IRA insights on this site.

Methodology

FEOC is defined in IIJA section 40207(a)(5) and incorporated into Section 30D by 26 CFR 1.30D-6. A vehicle is disqualified if any battery component is manufactured or assembled by a FEOC, or if any applicable critical mineral was extracted, processed, or recycled by a FEOC. Treasury permits de minimis allowances for certain trace materials and provides a transition rule for non-traceable battery materials through 2026.

This tool screens the cell-component pathway (Q1 through Q5) and the critical-minerals pathway (Q6 through Q8) separately, because the rule disqualifies on either ground. Unknown answers are surfaced rather than silently passed; in practice, a clean verdict requires affirmative supplier attestation, not the absence of contrary information.

For the full FEOC Stack framework with firm-by-firm supplier maps, mineral chain-of-custody analysis, and tracking of Treasury sub-regulatory guidance through the latest amendment, see the methodology one-pager. Or send the brief.