Frequently asked questions about energy efficient home improvements and residential clean energy property credits – Energy Efficient Home Improvement Credit – Qualified manufacturer

 

Updated FAQs were released to the public in Fact Sheet 2025-01 PDF, Jan. 17, 2025. This fact sheet contains all of the FAQs in one downloadable PDF.

Q1. What is a qualified manufacturer (QM) and does a manufacturer need to register with the IRS? (added Jan. 17, 2025)

A1. A qualified manufacturer means any manufacturer of specified property that enters into an agreement with the IRS that provides, generally, that such manufacturer will: (1) assign a product identification number to each item of specified property produced by such manufacturer, using a methodology that will ensure that such number (including any alphanumeric) is unique to each such item (PIN assignment requirement); (2) label such item with such PIN (PIN labeling requirement); and (3) make periodic written reports to the IRS of the PINs so assigned (periodic written report requirement). If a manufacturer wants to be considered a QM and produce specified property that would be eligible for the credit, it must register with the IRS through the IRS Energy Credits Online Portal. See Revenue Procedure 2024-31 and Publication 6046, Energy Efficient Home Improvement Credit Qualified Manufacturers: Registration Guide PDF the for more information.

Q2. Does a manufacturer need to register with the IRS as a QM for the manufacturer’s specified property to be eligible for the credit? (added Jan. 17, 2025)

A2. Yes. To be eligible for the credit for any item of specified property placed in service after Dec. 31, 2024, the specified property must be produced by a QM and the taxpayer must include a qualified product identification number (PIN) on the taxpayer’s tax return. Specified property means qualified energy property and any property described in section 25C(3)(B) (exterior windows, including skylights) or (C) (exterior doors). See Revenue Procedure 2024-31.

Q3. When will the IRS Energy Credits Online Portal be available for manufacturers to register to become QMs? Are there registration deadlines for 2024? (added Jan. 17, 2025)

A3. The IRS Energy Credits Online Portal will be available for manufacturers to register as QMs for the credit in early 2025. Please see IRS.gov for the latest information. Any manufacturer that submits its QM Registration Application and Agreement by April 30, 2025, will be deemed to have been a QM as of Dec. 31, 2024, provided that such QM Registration Application and Agreement is validated by the IRS. For these manufacturers deemed to be a QM as of Dec. 31, 2024, any specified property produced by them on or after Jan. 1, 2025, and on or before April 30, 2025, will be deemed to have been produced by a QM. Otherwise, no credit is allowed for any specified property produced by a manufacturer prior to the date that the IRS accepts a manufacturer as a QM.

Q4. How does a QM assign PINs to specified property? (added Jan. 17, 2025)

A4. If the IRS accepts a manufacturer’s QM Registration Application and Agreement, the IRS will send a certification to the manufacturer’s authorized representative through the IRS Energy Credits Online Portal. The IRS also will assign and issue a unique 4-character QM Code to the manufacturer through the IRS Energy Credits Online Portal.

Starting for property placed in service in 2026, QMs must assign a 17-character PIN unique to each item of specified property that requires a PIN. The PIN for each item of specified property is made up of three parts and may contain alphanumeric characters (including the common digits 0 to 9 and capital letters A to Z, other than I or O, but not special characters such as *, &, @, etc.). The first part is a 4-character “QM Code” assigned to the manufacturer by the IRS, the second part is a single-character “Product code” (assigned by the QM in accordance with a list of Product Codes on IRS.gov, on the IRS Energy Credits Online Portal, or in future published guidance) representing character 5 of the PIN, and the third part is a 12-character “Item Number” representing the last 12 characters of the PIN. The Item Number is chosen by the QM, must be unique to each item of specified property produced by the QM, and cannot have leading zeros. QMs report PINs to the IRS using the IRS Energy Credits Online Portal at least quarterly.

Q5. How does a QM provide PINs to taxpayers purchasing specified property? (added Jan. 17, 2025)

A5. A QM must label each item of specified property and furnish the PIN to taxpayers in accordance with section 6 of Revenue Procedure 2024-31. Generally, a QM may choose the method for labeling products (see examples in this answer below), provided that the PIN is furnished to the taxpayer no later than the following dates, depending on when the specified property is placed in service:

  • For specified property placed in service on or after Jan. 1, 2025, and before Jan. 1, 2026, (i) when the taxpayer places the specified property in service, (ii) when the taxpayer requests a PIN from the QM, or (iii) when the manufacturer becomes a QM, whichever is later (for this period just the QM Code is needed, in lieu of a full 17-character PIN described in A3 of this section and in the PIN requirements section);
  • For specified property placed in service on or after Jan. 1, 2026, (i) when the taxpayer places the specified property in service, or (ii) when the taxpayer requests a PIN from the QM, whichever is later.

For any specified property produced in calendar year 2025 and placed in service on or after Jan. 1, 2026, and to which only a QM Code has been assigned, the QM must assign and make the full 17-digit PIN available to taxpayers upon request.

Examples of methods a QM might choose to label specified property include adding the PIN to the specified property by affixing a label to it, or etching the PIN on the product itself. Alternatively, a QM may affix a label containing the PIN to the item’s packaging, print the PIN directly on the packaging, or include a document containing the PIN inside the item’s packaging. See the PIN requirements section for more information.

Q6. Does a manufacturer of insulation materials or systems (including air sealing materials or systems) need to register with the IRS to become a QM? (added Jan. 17, 2025)

A6. Insulation materials or systems are not specified property. If a manufacturer of insulation materials or systems produces no specified property, it does not need to register with the IRS to become a QM. Only manufacturers of specified property may register with the IRS to become QMs. If a manufacturer of insulation materials or systems also produces other property that is specified property, it must register with the IRS to become a QM in order for such specified property to be eligible for the credit.

Q7. How does a QM meet the periodic written report requirement? (added Jan. 17, 2025)

A7. A manufacturer meets the periodic written report requirement by submitting periodic reports (QM Reports) to the IRS electronically through the IRS Energy Credits Online Portal, as provided in section 7 of Revenue Procedure 2024-31. For items of specified property that leave a QM’s control and enter the stream of commerce on or after Jan. 1, 2025, and before Jan. 1, 2026, only one QM Report is required, and a QM must file that report by Jan. 15, 2026.