Is Canadian Solar (Recurrent Energy) a Foreign Entity of Concern (FEOC)?

Solar Panels · Guelph, Ontario, Canada

Company record last verified · federal list index as of

FEOC answer

Uncertain

Uncertain. Canadian Solar (Recurrent Energy) is not named on any of the 3 federal restricted-party lists screened for this record (DOD Section 1260H, BIS Entity List, UFLPA Entity List), but its FEOC status is unresolved and depends on ownership or component-level analysis.

  • Canadian-headquartered but substantial Chinese manufacturing. Founder is Chinese-Canadian. Most production in China raises FEOC supply chain questions. Requires detailed component-level analysis.
  • Flagged for review on the UFLPA Entity List (supply chain), not designated.
  • Not screened in this record: OFAC SDN List. No conclusion either way is drawn from that list.

Track Canadian Solar (Recurrent Energy)

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Federal list screening for Canadian Solar (Recurrent Energy)

Canadian Solar (Recurrent Energy) carries a result for 3 of the 4federal restricted-party lists below. "No screening record" means neither source covers that list; it is not a finding that the company is absent from it, and no claim on this page counts it as a clean result.

Results come from two places: the curated company record, and the live federal list index re-ingested from the agencies. Where they disagree the index wins and the row says so. The index can only add a designation, never clear one -- no confident match in the index is not evidence that a company is absent from a list.

Federal restricted-party list screening results
Federal listResultCheckedSource
DOD Section 1260H
U.S. Department of Defense
Not listed2026Official list
BIS Entity List
U.S. Department of Commerce, Bureau of Industry and Security
Not listed2026Official list
OFAC SDN List
U.S. Department of the Treasury, Office of Foreign Assets Control
No screening record
Not screened in this record
-Official list
UFLPA Entity List
U.S. Department of Homeland Security (FLETF)
Under review
supply chain
2024Official list

Ownership and country of organization

Country
Canada
Headquarters
Guelph, Ontario, Canada
Ultimate owner
Shawn Qu (Chinese-Canadian national, founder & chairman)
Ownership type
Public (NASDAQ: CSIQ)
Covered nation
No
U.S. manufacturing
Yes. Module assembly plant in Mesquite, Texas (5 GW).
Products
Solar modules, Solar cells, Energy storage solutions

Summary

Canadian-headquartered but substantial Chinese manufacturing. Founder is Chinese-Canadian. Most production in China raises FEOC supply chain questions. Requires detailed component-level analysis.

Canadian-listed but mostly Chinese-manufactured. US assembly helps but upstream supply chain needs scrutiny.

A clean list screen does not by itself establish that a company is outside the FEOC rules. Under OBBBA (P.L. 119-21), enacted July 4, 2025, and under IRS Notice 2026-15 (Feb 12, 2026), an entity is also prohibited if a specified foreign entity owns 25 percent or more of it, if such entities together own 40 percent or more, if they hold 15 percent or more of its debt, or if one can appoint a board member or senior officer. Those tests require the cap table and debt structure, which this page does not cover.

How this answer is determined

The prohibited-foreign-entity restrictions on the 45Y, 48E and 45X clean energy credits were added by OBBBA (P.L. 119-21), enacted July 4, 2025 and are administered under IRS Notice 2026-15 (Feb 12, 2026). A company answers "yes" on this page when it is named on a federal restricted-party list, or when it is organized in a covered nation (China, Russia, Iran or North Korea). Where ownership or component sourcing leaves the question genuinely open, the answer is "uncertain" rather than a clean result -- and that holds even for a company organized in a covered nation, because a record flagged for component-level analysis is answering a narrower question than the entity-level test.

A separate ownership and control test can make a company prohibited even with a clean list screen: a specified foreign entity can appoint a covered officer (board member, president, CEO or CFO); a single specified foreign entity owns 25 percent or more; specified foreign entities together own 40 percent or more; specified foreign entities together hold 15 percent or more of the entity's debt. Those tests need the cap table and debt structure and are not evaluated here.

Sources for this record

  • SEC EDGAR - Canadian Solar 20-F
  • CBP UFLPA data

Suppliers in Solar Panels with no federal designation

This page is informational and is not legal or tax advice. Federal list data is drawn from publicly available government sources and may lag the agencies' own updates; verify any determination against the official list linked above and with qualified counsel before relying on it.