Built in America: How DCE Solar Positions Clients for Domestic Content Compliance

The rules are getting stricter. The deadlines are getting closer. And the stakes have never been higher.

With the passage of the Reconciliation Bill in July 2025, the domestic content requirements tied to clean energy tax credits are no longer a planning consideration. They are a construction prerequisite. For EPCs, developers, and investors putting utility-scale solar projects in the ground right now, compliance with these requirements is the difference between a project that pencils out and one that does not.

DCE Solar has spent 17 years building racking solutions on American job sites. Our product lines were not retrofitted for domestic content. They were built to perform in the field, and the supply chain behind them reflects the same standard.

What the Law Actually Requires

Under the IRA and OBBBA framework, solar projects claiming the Section 48E Investment Tax Credit or Section 45Y Production Tax Credit must satisfy two separate domestic content tests:

• Steel and Iron: 100% of structural steel and iron components must be manufactured in the United States. This includes piles, rails, and rebar. No exceptions.

• Manufactured Products: A rising percentage of manufactured product components must be U.S.-produced. That threshold is 45% for projects beginning construction in 2025, 50% in 2026, and 55% in 2027 and beyond. Solar trackers, modules, and inverters fall into this category.

• Prohibited Foreign Entity (PFE) Restrictions: Effective for facilities beginning construction after December 31, 2025, projects that include any material assistance from a PFE are ineligible for credits. Supply chain provenance is now a legal question, not just a sourcing preference.

Steel Is the Foundation. Literally and Legally.

Before getting into product specifics, it is worth understanding just how much steel a utility-scale solar project actually consumes. Industry data puts it at 35 to 45 tons per megawatt of installed capacity. The majority of that weight lives in the foundation, in the form of driven piles, torque tubes, and racking rails. A typical solar facility drives roughly 500 steel piles per megawatt, and projects exceeding 100,000 piles are not uncommon.

Scaled to the pace of U.S. solar deployment, that volume becomes significant fast. The industry added 30.8 GW of utility-scale solar in 2024, 27.2 GW in 2025, and developers plan to add 43.4 GW in 2026. At 35 to 45 tons per MW, a single year of utility-scale solar deployment consumes somewhere in the range of 1 to 1.5 million tons of steel. That is roughly 1.5% of total U.S. annual steel shipments from a single end-use sector.

The domestic content mandate makes every ton of that steel count twice: once for the structure it holds up, and again for the tax credit compliance it enables. The IRS is not counting bolts or clamps. It is counting structural steel, and every pile and rail must trace back to a U.S. mill.

Does U.S. Steel Capacity Create Healthy Competition?

On the racking and tracker side of the equation, progress has been real. According to SEIA's Supply Chain Dashboard, there are now nearly 70 tracking and racking manufacturing facilities operating in the United States, enough capacity on paper to cover all domestic demand for trackers and racking rails. That number did not exist before the IRA. The domestic manufacturing ecosystem has rebuilt itself at a pace the industry did not think possible in 2022.

But capacity on paper and capacity in practice are two different things. Through late 2025, U.S. domestic steel mills were booked solid. The Section 232 tariff, which was doubled from 25% to 50% in June 2025, effectively shut off the imported steel release valve that developers had historically relied on when domestic supply got tight. Mills became oversold, and developers who were prepared to pay a premium often could not get the tonnage they needed on the timeline their projects required.

The result was a ripple effect into project schedules. Some developers stretched timelines. Others revised financial models upward on capital expenditure. Others quietly deprioritized domestic content compliance because the steel simply was not available to qualify.

So yes, domestic steel capacity for solar is growing. Yes, more racking and tracker facilities are online than ever. And yes, that growth is beginning to create real competition, which will put downward pressure on pricing over time. But the demand curve heading into 2026 and beyond, with 43 GW of planned utility-scale additions, means the market has not yet reached a point of comfortable surplus. Supply is tight, timelines are compressing, and procurement decisions made late in project development can derail compliance.

Fixed Tilt: Where the Math Works in Your Favor

Under Treasury guidance (Notice 2025-08), ground-mounted fixed-tilt systems carry a safe harbor cost multiplier of 0.75. That is the second-highest multiplier in the solar PV category. It means fixed-tilt projects have more room to qualify for the domestic content bonus credit before they need to source every last component domestically.

DCE Solar's Fixed Tilt ground mount systems are built with domestically produced structural steel throughout. All piles, rails, and primary structural members satisfy the 100% steel and iron requirement. That takes the most rigid compliance box completely off the table before procurement teams ever open a tracker quote.

For EPCs and project developers working against the 2026 construction start deadline, fixed-tilt systems offer a faster, cleaner path to compliance documentation. Fewer moving components mean fewer supplier attestations to collect and a cleaner audit trail for investors and tax counsel.

Understanding the Multiplier: What 0.75 vs. 0.57 Actually Means

The IRS created the safe harbor system so developers do not have to audit every supplier on a project to prove domestic content compliance. Instead of collecting direct cost data from every manufacturer in the supply chain, developers can use a set of preset IRS tables that assign each project type a baseline score. That score is the multiplier.

Think of it as a scoring base. The multiplier represents how many cents of every dollar of your project’s total value the IRS considers subject to the domestic content calculation. Fixed-tilt ground-mount systems are assigned 0.75, meaning 75 cents of every dollar counts. Single-axis tracker systems are assigned 0.57, meaning only 57 cents of every dollar counts.

A higher multiplier gives you more room. Both project types must still clear the same domestic content percentage threshold (50% in 2026, 55% in 2027 and beyond). But when fixed-tilt’s larger base runs that math, each foreign-sourced component takes a smaller proportional bite out of your compliance score. You have more cushion before you fall below the threshold.

Tracker projects start with a smaller base. That does not mean they cannot qualify. It means every sourcing decision carries more weight. A tracker manufacturer with a loose or foreign-heavy supply chain can burn through a project’s compliance headroom quickly. A tracker manufacturer with a disciplined domestic supply chain preserves it.

For developers under deadline pressure, the multiplier gap between fixed-tilt and trackers is not a minor technical footnote. It is a procurement decision that determines whether your project qualifies for the bonus credit before a single pile goes in the ground.

Tracker: Compliance Without Compromise

Single-axis tracker projects carry a 0.57 safe harbor multiplier under current IRS tables. That tighter weighting means every component sourcing decision has a larger impact on whether a tracker project clears the manufactured product threshold. It is not a reason to avoid trackers. It is a reason to choose your tracker manufacturer carefully.

DCE Solar's Tracker platform is built around a U.S.-based supply chain. Key structural components are domestically sourced and manufactured, positioning tracker projects to meet both the steel and iron mandate and the rising manufactured product thresholds.

What sets the Tracker apart from larger tracker manufacturers is not just the product. It is the documentation support and supply chain transparency our team provides to EPCs navigating the compliance process. When a lender or tax equity partner asks for supplier attestations, DCE Solar project teams are not starting from scratch.

Takeaway: What IPPs and Developers Should Do Right Now

The domestic steel market is more competitive than it was three years ago. That is good news for the industry in the long term. But competitive does not mean easy to access, and growing does not mean available on your schedule. Here is what developers and IPPs should take away from the current market conditions:

• Lock in your racking and steel supplier early. Domestic mills have been running tight, and the demand curve heading into late 2026 will only increase pressure on supply. Developers who treat steel procurement as a late-stage decision are the ones who miss construction start deadlines, and in 2026, a missed construction start is a missed tax credit.

• Treat compliance documentation as a deliverable, not an afterthought. Tax equity investors and lenders are asking for supplier attestations and domestic content modeling at project origination. If your racking or tracker manufacturer cannot produce clean documentation quickly, that delay costs you financing time and deal certainty.

• Do not assume all domestic steel is equal under the law. The IRS requires that all manufacturing processes for structural steel occur in the United States. Domestically assembled racking using foreign-fabricated steel does not qualify. Ask your supplier explicitly: where was the steel melted, formed, and fabricated?

• Use growing capacity to your advantage, but do not wait for prices to fall. More domestic racking and tracker facilities online means more competition and eventually better pricing. But the 2026 demand surge will absorb much of that new capacity. The window of price pressure has not arrived yet. Locking in now protects schedule and budget.

• Diversify your supplier relationships. The developers who fared best through the 2025 steel crunch were the ones with more than one domestic sourcing option. Multi-project pipelines should not run through a single supplier. Build redundancy into your procurement strategy the same way you build it into your interconnection queue.

DCE Solar's Commitment to U.S. Manufacturing

DCE Solar is not a foreign-based company that localized a product line to chase tax credit eligibility. We are an American contractor and manufacturer, and we have been one since 2009. Our fabrication partners and supply chain relationships are domestic by default, not by compliance design.

Our clients benefit from that foundation in ways that go beyond tax compliance:

• Shorter lead times from domestic fabrication partners mean less schedule risk on tight project timelines.

• Reduced tariff exposure in a trade environment that has become increasingly unpredictable.

• Cleaner compliance documentation because our supply chain is legible. We know where our steel comes from.

The Window Is Open. Not for Long.

Projects that begin construction before the end of 2026 and placed into service by December 31, 2027 can still qualify for the full suite of tax credit benefits under the OBBBA framework. After that, the credits phase down, the PFE restrictions tighten, and the compliance bar continues to rise.

If your project is in development now, the racking and tracker decisions you make in the next few months will determine your compliance posture at construction start. DCE Solar's Fixed Tilt and Tracker Twin solutions are built to help you get there.

We are not selling compliance. We are selling products that are already built for it.

Sources

• U.S. IRS, Domestic Content Bonus Credit Guidance: Notice 2023-38, Notice 2024-41, Notice 2025-08. irs.gov/credits-deductions/domestic-content-bonus-credit

• Norton Rose Fulbright, "Updated Domestic Content Calculations," March 2026. projectfinance.law

• Grant Thornton, "Energy incentives under OBBBA: What you need to know," 2025. grantthornton.com

• Arnold & Porter, "From IRA to OBBBA: A New Era for Clean Energy Tax Credits." arnoldporter.com

• Solar Energy Industries Association (SEIA), Solar & Storage Supply Chain Dashboard, June 2026. seia.org

• SEIA, Solar Market Insight Report: 2025 Year in Review, March 2026. seia.org

• American Clean Power Association (ACP), The State of Clean Energy Manufacturing 2026. cleanpower.org

• PV Magazine USA, "The steel supply crunch threatening U.S. solar ambitions," September 2025. pv-magazine-usa.com

• Solar Builder Magazine, "Reducing one pound of steel per foot length of every pile," 2019. solarbuildermag.com

• Sprott, "Steel Meets Rising Global Electricity Demand," 2025. sprott.com

• U.S. Energy Information Administration (EIA), Preliminary Monthly Electric Generator Inventory, December 2025. eia.gov

• Congress.gov / Library of Congress, "Domestic Content Requirements for Electricity Tax Credits in the IRA," January 2025.

• Solar Power World, "More details on IRA domestic content bonus revealed today by Treasury, IRS," May 2024. solarpowerworldonline.com

This editorial is for informational purposes only and does not constitute tax or legal advice. Consult qualified tax counsel for project-specific compliance analysis.