REAP guide

REAP foreign component rule for solar and wind

Last updated October 2, 2026. Reflects USDA's October 1, 2026 final rule.

Under the October 2026 REAP rule, a solar PV system or wind turbine is not eligible if any component was made in a country named as a foreign adversary in 15 CFR 791.4. (7 CFR §4280.122(b)(19)) Projects installed before the rule's publication date are exempt. (7 CFR §4280.122(b)(19)) The rule was published on October 1, 2026 (Federal Register 2026-20178).

What the rule says

The rule lists projects that cannot get a REAP grant. (7 CFR §4280.122(b)) One of them is a project that includes a solar photovoltaic system or wind turbine "consisting of any component made in a country named as a foreign adversary as listed in 15 CFR 791.4." (7 CFR §4280.122(b)(19))

The rule says "any component." It does not set a percentage or a minimum value. (7 CFR §4280.122(b)(19)) USDA's discussion of the application requirements gives examples of solar system components: the panel manufacturer, inverter manufacturer, racking manufacturer, and monitoring software (rule discussion, Federal Register 2026-20178).

A project that is exempt still has to meet every other completeness and eligibility requirement in the rule. (7 CFR §4280.122(b)(19))

Rooftop and ground mount are both covered

The ban is not limited to large ground arrays. USDA's discussion says solar and wind systems, "both ground mount and roof mount," with any component made in a foreign adversary country are not eligible (rule discussion, Federal Register 2026-20178). Ground-mounted systems on cropland face a separate ban. See the REAP cropland rule.

The exemption for older projects

Projects installed before the publication date of the regulation are exempt from the component ban. (7 CFR §4280.122(b)(19)) The regulation was published October 1, 2026 (Federal Register 2026-20178). USDA says the exception gives applicants time to transition to components made in countries not named as foreign adversaries (rule discussion, Federal Register 2026-20178).

The rule text uses the word "installed." (7 CFR §4280.122(b)(19)) The rule does not say how to treat a system that was partly installed on October 1, 2026, or a system that had parts replaced after that date. If your project falls in one of those cases, confirm with your State Energy Coordinator before you apply.

Which countries are on the list

REAP does not keep its own list. It points to 15 CFR 791.4, a Commerce Department regulation. (7 CFR §4280.122(b)(19)) We checked 15 CFR 791.4 on eCFR on October 3, 2026. It names these foreign governments and foreign non-government persons, in its own words:

The Commerce Department can revise this list, and revisions take effect when published in the Federal Register (15 CFR 791.4(b)). Check the current list on eCFR before you buy equipment.

Foreign ownership of the business

A second rule looks at who owns the applicant, not where the parts came from.

• Businesses headquartered in countries determined to be foreign adversaries under 15 CFR 791.4 are not eligible for REAP. (7 CFR §4280.120(b)(9))
• If a business has any foreign investment or ownership, USDA will evaluate whether it can take part in REAP "consistent with applicable law." (7 CFR §4280.120(b)(9))
• The application must name any foreign owners and give each one's percentage of ownership. (7 CFR §4280.131(a)(12))

The rule does not say what level of foreign ownership, short of a foreign adversary headquarters, would make a business ineligible. If your business has any foreign owners, raise it with your State Energy Coordinator early. For more on who counts as the applicant, see the highest-level owner rule.

What the application asks for

For solar and wind projects, the applicant must identify the country of origin for all system components. (7 CFR §4280.131(b)(5)) The rule does not exempt systems installed before October 1, 2026 from this question. (7 CFR §4280.131(b)(5)) The rule does not say what proof, if any, USDA will accept or require to back up the country of origin you report. The Notice of Funding Opportunity or your State Energy Coordinator may give more detail.

Practical advice: ask your installer for paperwork

The steps below are our suggestions, not USDA requirements. They can help you answer the country of origin question accurately and avoid surprises.

1. Get a written equipment list. Ask your installer for the make, model, and manufacturer of every component. For solar, that includes panels, inverters, racking, and monitoring, the same examples USDA uses in its discussion (rule discussion, Federal Register 2026-20178).
2. Ask where each item was made. A brand's home country is not always where the product was made. Ask for the country of manufacture for each item, in writing.
3. Keep spec sheets and shipping papers. Manufacturer data sheets, packing lists, and invoices often show where a product was made. Save them with your project file.
4. Put it in the contract. For a new system, ask the installer to state in the contract that no component was made in a country listed in 15 CFR 791.4, and to tell you before substituting equipment.
5. Record your install date. If you are relying on the exemption for systems installed before October 1, 2026, keep records that show when the system was installed, such as the final invoice, inspection sign-off, or interconnection approval.

The rule does not define where a component counts as "made" when its parts come from several countries. If your supplier reports more than one country for a single product, ask your State Energy Coordinator how to report it.

Where to go next

Read the full guide to the 2026 REAP rule, compare the old and new rules, or check your eligibility. You can also see who qualifies, estimate your score, and find out whether REAP is open. If you want help sorting out component documentation, CGF can help.

Related guides

• REAP cropland rule for ground-mount solar and wind
• REAP highest-level owner rule
• REAP grant amounts
• REAP old vs. new rules