Is Sungrow (Hydrogen Division) a Foreign Entity of Concern (FEOC)?
Hydrogen & Electrolyzers · Hefei, Anhui, China
Company record last verified · federal list index as of
FEOC answer
Yes
Yes. Sungrow (Hydrogen Division) is organized in China, a covered nation under the FEOC rules, which makes it a foreign entity of concern for IRA clean-energy tax credit purposes. It is not named on any of the 3 federal restricted-party lists screened for this record (DOD Section 1260H, BIS Entity List, OFAC SDN List).
- Organized in China, a covered nation under the FEOC rules (China, Russia, Iran, North Korea).
- Not named on any of the 3 federal restricted-party lists screened for this record (DOD Section 1260H, BIS Entity List, OFAC SDN List). The covered-nation test, not a list designation, is the basis for this answer.
- Not screened in this record: UFLPA Entity List. No conclusion either way is drawn from that list.
Track Sungrow (Hydrogen Division)
Federal list designations change without notice. Get an email when Sungrow (Hydrogen Division) is added to, or removed from, any screened list.
Federal list screening for Sungrow (Hydrogen Division)
Sungrow (Hydrogen Division) 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 list | Result | Checked | Source |
|---|---|---|---|
DOD Section 1260H U.S. Department of Defense | Not listed | 2026 | Official list |
BIS Entity List U.S. Department of Commerce, Bureau of Industry and Security | Not listed | 2026 | Official list |
OFAC SDN List U.S. Department of the Treasury, Office of Foreign Assets Control | Not listed | 2026 | Official list |
UFLPA Entity List U.S. Department of Homeland Security (FLETF) | No screening record Not screened in this record | - | Official list |
Ownership and country of organization
- Country
- China
- Headquarters
- Hefei, Anhui, China
- Ultimate owner
- Cao Renxian (Chinese national, founder & chairman)
- Ownership type
- Public (SHE: 300274)
- Covered nation
- Yes -- China
- U.S. manufacturing
- No US manufacturing for hydrogen products.
- Products
- PEM electrolyzers, Alkaline electrolyzers, Hydrogen production systems
Summary
Chinese-headquartered company. Subject to FEOC restrictions as a covered nation entity.
Sungrow's hydrogen division. Leveraging power electronics expertise for electrolyzer production.
A FEOC determination is entity-level. Whether a specific project or component qualifies for the 45Y, 48E and 45X credits also depends on material-assistance cost ratios and the applicable begin-construction or sale date under IRS Notice 2026-15 (Feb 12, 2026), which this page does not evaluate.
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
- Sungrow Annual Report
- BIS Consolidated Screening List
Where Sungrow (Hydrogen Division) sources its components
A supplier can be named on no federal list and still sit on top of a supply chain that is. The map traces this product to the mines and refiners behind each input.
Sungrow (Hydrogen Division) supply chain mapSuppliers in Hydrogen & Electrolyzers 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.