What the IRS Has Issued
1. Revenue Procedure 2024-31 (Issued October 24, 2024)
Establishes how manufacturers become Qualified Manufacturers (QMs) under § 25C(h).
To qualify, manufacturers must:
Register with the IRS and enter into an agreement.
Assign a unique Product Identification Number (PIN) to each item of specified property they produce.
Label each product with its PIN.
Submit periodic reports of assigned PINs via the IRS Energy Credits Online (ECO) Portal.
2. Proposed Regulations (October 2024)
Clarify definitions, including new terms like "enabling property" and "enabled property".
Provide safe harbors, instructions for credit calculation, and more detailed guidance for QMs.
Taxpayers may rely on the proposed regulations now if they consistently follow them in full.
Public hearing scheduled for January 21, 2025; written comments accepted through December 24, 2024.
3. IRS FAQ (Last Updated May 2025)
For property placed in service on or after January 1, 2025, taxpayers must include a 17-character PIN per qualifying item—unless the product is from a QM.
For 2025 only, taxpayers may use the shorter 4-character QM Code in lieu of a full PIN (e.g., for specified property or “enabling property”).
Enabling property (like electrical panels needed to support qualifying equipment) can always use the QM Code—even after 2025.
Certain items like insulation or home energy audits do not require PINs.
4. Notice 2024-13 (December 2023)
Announces intent to propose regulations implementing the PIN requirement.
Outlines a proposed 17-digit PIN structure (with QM Code, product code, year, and item number).
Requests comments from manufacturers and others on feasibility, labeling, consumer awareness, and more.
5. Early 2025 Transition Details for Manufacturers
The IRS Energy Credits Online Portal will open early 2025 for manufacturer QM registrations.
Manufacturers that submit their registration by April 30, 2025, will be deemed effective as of December 31, 2024. That means products produced starting January 1, 2025, will qualify, even if formal acceptance occurs later.
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