Battery Pulse

Supplier certification checker

A supplier's FEOC certification is a starting point, not a finish line. Go through yours against what the law requires, what a good one covers, and what the public record might say, and see the gaps before you rely on it.

Have the certification in front of you. Twelve questions, about three minutes. Nothing you enter leaves your browser.

1. What the law requires
Is it signed under penalties of perjury?The lawThe law requires this for a buyer to rely on it.
Does it certify what the law asks?The lawEither that the products weren't made by a prohibited foreign entity, or the direct costs, including those attributable to prohibited foreign entities.
Will you and the supplier both keep it for at least six years?The lawThe law requires both sides to keep it.
Can you hand it to the IRS on request?The lawNo confidentiality term should stop you.
2. Whether it fits your deal
Does it name the same legal entity as your contract?Good practiceNot just the group or brand name.
Does it cover the exact products you're buying?Good practiceModels or part numbers, not "all our products".
Does it cover the shipments or period in question?Good practiceA date, or the deliveries it applies to.
Is the signer an officer who can bind the supplier?Good practiceA name and title, not just a company stamp.
Does the supplier promise to tell you if anything changes?Good practiceOwners, lenders and licenses can change after signing.
3. What the public record says
Have you checked the supplier and its parents against the US government lists the law names?Reason to knowUnder every form of each name.
Do you know who owns the supplier at the top of its chain?Reason to knowFrom filings or registries, not only the supplier's word.
Has anything public suggested covered-nation owners, lenders or technology licenses?Reason to knowFor example, a state-owned investor, a loan from a bank based in a covered nation, or an IP license signed or changed since 4 July 2025.

Your gaps

A checklist on your answers, not legal or tax advice, and not a view on whether you can rely on a particular certification.

Why this matters

While Treasury's safe harbor tables are pending, and for a short window after they're issued, a buyer working out the material assistance cost ratio may rely on a supplier's certification. The certification must be signed under penalties of perjury and kept by both the supplier and the buyer for at least six years, and given to the IRS on request. A buyer may not rely on one it knows, or has reason to know, is inaccurate.

That last test is why the public record matters. A certification can't tell you what's in a supplier's filings; only looking can. Suppliers also face a penalty for inaccurate certifications, so expect them to read one carefully before signing.

Sources: 26 USC 7701(a)(52)(D)(iii); 26 USC 6695B; IRS Notice 2026-15. Labels: The law marks what the statute requires; Good practice and Reason to know are Battery Pulse's view of what a careful buyer checks. Rules current as of .

Next: see where your cost ratio stands with the cost ratio calculator, or rank your suppliers by what's at stake.