The bill bars executive agencies from using federal funds to procure crystalline silicon photovoltaic (PV) solar panels manufactured or assembled by entities domiciled in, or subject to influence or control by, the People’s Republic of China (PRC), as designated by DHS. It directs the Office of Management and Budget (OMB) to issue standards and the Federal Acquisition Regulation (FAR) Council to amend the FAR within 180 days, and it forbids use of government purchase cards to buy covered panels.
The Act creates a narrow waiver procedure requiring an agency head’s certification that a covered entity is the only viable source and joint approval by the Secretary of State and the Secretary of Homeland Security. It also mandates a Comptroller General (GAO) report on prior PRC-sourced purchases, an OMB-funded federally funded research and development center (FFRDC) study of the domestic market, and sets DHS as the determiner of which firms qualify as “covered entities.” Compliance deadlines, origin-verification needs, and the definition limited to crystalline silicon PV cells and modules are the operational levers that will matter to procurement, legal, and supply-chain teams.
At a Glance
What It Does
The bill requires OMB, in consultation with GSA, to develop standards within 180 days that bar federal contracts, subcontracts, grants, subgrants, and government purchase card purchases of crystalline silicon PV panels manufactured or assembled by covered entities. The Federal Acquisition Regulatory Council must amend the FAR on the same timeline to implement the contract prohibition.
Who It Affects
Federal contracting officers, GSA and FAR stakeholders, agencies that run federally funded solar projects, and suppliers that participate in federal solicitations for crystalline silicon PV modules. DHS and State play decision roles for waivers and covered-entity designations.
Why It Matters
It creates a rapid, statutory pivot in federal solar procurement focused on origin-based supply-chain security rather than product performance, forcing agencies and vendors to retool contracting clauses, vendor vetting, and sourcing plans within a compressed timeline and altering market access for firms tied to the PRC.
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What This Bill Actually Does
The Act targets federal procurement of crystalline silicon photovoltaic (PV) solar panels by prohibiting federal funds from being used to buy panels manufactured or assembled by entities the Department of Homeland Security designates as domiciled in, or subject to influence or control by, the People’s Republic of China. OMB must write standards within 180 days, working with the General Services Administration, for how agencies implement that ban, and the FAR Council must put the rule into the FAR so contracts and subcontracts reflect the new restriction.
Operationally, the bill reaches not only formal contracts and subcontracts but also grants and government-issued purchase cards, forcing agencies to change ordering practices, update contract clauses, and verify origins before procurement. The statutory definition of “solar panel” is limited to crystalline silicon PV cells and modules, which narrows the scope but leaves other photovoltaic technologies and upstream inputs (polysilicon, wafers, frames) outside the text’s explicit coverage.Agencies can obtain a waiver if the agency head certifies a covered entity is the only viable source and the Secretaries of State and Homeland Security jointly approve.
OMB must be notified of waiver requests and report quarterly to specified congressional committees on approvals or denials. The bill also requires GAO to report within 275 days on how much federal agencies procured from covered entities before the ban, and it tasks OMB with contracting an FFRDC within a year to study the domestic solar manufacturing market, technological trajectory, and global supply chain.Practical consequences will focus on origin verification, contracting revisions, and market access.
Procurement teams will likely need new certification clauses, supplier attestation procedures, and documentary evidence of where modules were assembled. For vendors, the statutory prohibition and DHS’s designation authority create an immediate compliance risk for firms with PRC-linked operations; for agencies, the short implementation timeline and reporting obligations create administrative and budgetary pressures not addressed elsewhere in the bill.
The Five Things You Need to Know
OMB must issue standards within 180 days (in consultation with GSA) prohibiting federal funds from buying crystalline silicon PV panels manufactured or assembled by DHS-designated covered entities and barring government purchase-card buys of such panels.
The Federal Acquisition Regulatory Council must amend the FAR within 180 days to implement the procurement and subcontract prohibition for federal contracts and subcontracts.
An executive agency head may request a waiver only by certifying the covered entity is the only viable source; the Secretary of State and Secretary of Homeland Security must jointly approve any waiver, and OMB must report waiver requests and outcomes quarterly to specified congressional committees.
The Comptroller General must deliver a report within 275 days on the dollar amount and quantities of crystalline silicon PV panels procured by federal departments and agencies from covered entities.
OMB must seek to contract with a federally funded research and development center within one year to study the domestic solar panel market, technology pace, and global supply chain; OMB then submits that study to several Senate and House committees.
Section-by-Section Breakdown
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Short title
States the Act’s short title: "Keep China Out of Solar Energy Act of 2025." This is a formal placement item but signals the statute’s singular policy aim — to exclude PRC-linked entities from federal crystalline silicon PV procurement.
OMB standards and government purchase card prohibition
Directs OMB (with GSA consultation) to develop standards and guidelines within 180 days requiring agencies to withhold federal funds from contracts, subcontracts, grants, and subgrants for solar panels manufactured or assembled by covered entities, and to forbid government-issued purchase cards from buying such panels. Practically, this provision will drive template language for solicitations, vendor self-certifications, documentary evidence requirements, and internal controls for purchase cards.
FAR amendment mandate
Requires the Federal Acquisition Regulatory Council to amend the FAR within 180 days to implement the procurement prohibition for federal contracts and subcontracts. This creates a rulemaking and contracting workload for the FAR Council, GSA, and agency legal offices to draft clauses, flow-down requirements for subcontracts, and noncompliance remedies consistent with the new statutory bar.
Waiver process and congressional reporting
Allows agency heads to request a waiver only when they certify that the covered entity is the only viable source; the waiver needs joint approval by the Secretary of State and the Secretary of Homeland Security. The section also requires OMB notification and quarterly reports to named Senate and House committees listing waiver requests and their dispositions. This sets up a narrow, governmental-signoff path for exceptions while creating a public oversight trail through quarterly reporting.
Comptroller General procurement report
Directs the GAO to report to Congress within 275 days on the amount of crystalline silicon PV panels federal departments and agencies procured from covered entities. That report will provide baseline data on federal exposure to PRC-linked sources and will be a key input for oversight and for agencies making sourcing decisions post-ban.
FFRDC study and definitions
Section 5 tasks OMB with contracting an FFRDC within one year to study domestic manufacturing capacity, technology advancement pace, and the global solar supply chain; OMB must submit the study to several Senate and House committees. Section 6 defines crucial terms: DHS determines which firms are "covered entities," "executive agency" follows Title 41 definitions, and "solar panel" is narrowly defined as crystalline silicon PV cells and modules. Together these provisions allocate who decides scope and provide the study framework to assess medium-term capacity and workforce implications.
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Explore Energy in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Domestic crystalline silicon PV manufacturers — the most direct beneficiaries because the federal market will be closed to PRC-linked competitors, potentially increasing federal contracting opportunities and incentives for investment in U.S.-based assembly and manufacturing capacity.
- Federal national-security and supply-chain risk teams — they gain a statute-backed tool to limit purchases from entities DHS identifies as subject to PRC influence or control, simplifying policy levers for source-origin restrictions.
- Contract compliance and verification vendors — companies that provide origin-tracing, supply-chain audits, and conformity-assessment services will see increased demand as agencies and suppliers implement documentation, attestation, and audit processes.
Who Bears the Cost
- Federal procurement offices and agency program managers — they must redesign solicitations, add origin-verification controls, train contracting officers, and manage waiver requests and reporting within compressed timelines, increasing administrative workload and near-term costs.
- U.S. and foreign suppliers with PRC-linked manufacturing or assembly operations — firms that previously sold crystalline silicon modules into federal channels will lose market access unless they restructure operations or obtain a waiver.
- Agencies running large federally funded solar projects and taxpayers — reduced supplier competition or the need to source higher-cost suppliers could increase project costs and slow deployment of federally funded solar installations, at least in the short to medium term.
Key Issues
The Core Tension
The bill pits a straightforward supply‑chain security objective — excluding PRC‑influenced manufacturers from federal crystalline silicon PV procurement — against operational practicality and clean‑energy deployment goals: safeguarding origin and enforcing the ban requires detailed, resource‑intensive verification and may raise costs or slow projects, but loosening rules reduces the intended security effect; there is no simple mechanism that fully secures supply chains without imposing real procurement and market trade‑offs.
Several practical and legal implementation questions are unresolved. First, the statute relies on DHS to determine which firms are "subject to influence or control," a fact-intensive and potentially opaque determiner that agencies and vendors must monitor.
DHS designations will drive compliance risk, but the bill contains no procedures for notice, appeal, or timely publication of that list, which could lead to uncertainty for contracting officers and suppliers.
Second, verifying the country of manufacture or assembly for crystalline silicon PV modules is technically and administratively complex. PV supply chains are multi-stage and global: polysilicon, ingots, wafers, cells, and module assembly often cross borders.
The bill focuses on where panels are manufactured or assembled, not on upstream inputs, creating opportunities for circumvention via third-country assembly or minor processing steps. Agencies will need to define acceptable documentary evidence, supplier attestations, and audit rights, yet the statute leaves those key operational standards to OMB and the FAR rulemaking.
Finally, the 180-day deadlines for standards and a FAR amendment and the narrow waiver standard create timing and capacity pressures. Agencies may face short-term supply gaps and higher prices; the FFRDC study required within a year will help inform longer-term policy but comes too late to ease immediate procurement disruptions.
The law also narrows covered products to crystalline silicon PV modules, leaving other PV technologies and many upstream components outside the constraint, which could shift procurement behavior in unexpected ways and create patchwork market effects.
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