Article

U.S.-assembled battery storage systems can still be vulnerable to foreign entity of concern (FEOC) exposure due to upstream ownership and materials processing. Despite the belief that domestic assembly offers protection from FEOC risks, many suppliers remain linked to Chinese entities or prohibited foreign components.

Updated FEOC guidelines from the One Big Beautiful Bill Act (OBBBA) create uncertainty in the energy storage sector, affecting counterparty selection and procurement structuring. Developers may face higher costs and project delays if upstream material requirements tighten in the next 12 to 24 months, as establishing compliant processes can take significant time. The risks associated with FEOC are often underestimated in the industry.