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Supply Chain

Solar Supply Chain Traceability Software

Provenance tracking from raw material to installed module — so you can prove where every component came from, screen it against the lists that matter, and produce chain-of-custody records that survive an audit.

Tier-by-tier provenance PFE + UFLPA screening Supplier certification cascade Chain-of-custody records

A solar module is the end of a long chain: quartz becomes polysilicon, polysilicon becomes wafers, wafers become cells, cells become modules. Three different regulatory regimes now demand that you can trace that chain — and each asks a different question. FEOC/PFE rules ask who owned and produced each input, for tax-credit eligibility. UFLPA asks whether any input touched Xinjiang, for customs clearance. AD/CVD orders ask whether duties apply. The modules are the same; the records required are not.

Provenance is a graph, not a spreadsheet

Most teams track this in spreadsheets that fall apart the moment an auditor asks “prove it.” We model the supply chain the way it actually behaves — as a graph of nodes, each carrying entity status, country of origin, direct cost, and the supplier certification that backs it up:

  • Critical mineral extraction — who extracted it, and where
  • Processing and refining — the processor’s entity status
  • Constituent-material production — polysilicon, wafers, active materials
  • Component manufacturing — cells, modules, inverters, trackers
  • Assembly and facility integration — installer and integrator
  • Project ownership and credit transfer — the taxpayer and any transferee

Because it’s a graph, questions that are hard in a spreadsheet become straightforward: what percentage of this module’s cost traces to a prohibited entity, which shipments share an at-risk polysilicon lot, and where does the documentation have a gap.

Screening against the lists that matter

Provenance is only useful if it’s checked against the right lists. The system screens every entity against the OFAC SDN list, the BIS Entity List, the UFLPA Entity List, and the DoD NS-CMIC list, and it flags the case that gets companies in trouble: a supplier certification that is contradicted by public data. That “reason to know” screen is what separates a defensible position from a hopeful one.

Certification cascade and audit trail

The due-diligence standard extends to every tier, and suppliers are expected to cascade certification obligations downstream — your tier-one supplier collects from tier two, and so on. We build the workflow that manages those certifications: who has signed, what they attested to, when it expires, and where a fresh attestation is needed. Every record is retained on the schedule the rules require, so when a determination is questioned years later, the provenance is already assembled rather than reconstructed under pressure.

This is the same discipline behind our automated compliance reporting work — turning scattered source data into documentation that stands up on its own.

This page describes software capabilities and summarizes publicly available regulatory guidance as of 2026. It is not legal advice. Traceability requirements under FEOC/PFE, UFLPA, and AD/CVD rules are evolving — verify specific obligations against current guidance and qualified counsel.

Frequently asked questions

Why does solar supply chain traceability matter now?

Three separate regimes now demand provenance: FEOC/PFE rules for tax-credit eligibility, the Uyghur Forced Labor Prevention Act (UFLPA) for customs clearance, and antidumping/countervailing duty (AD/CVD) orders. Each asks a different question about the same modules, and passing one does not satisfy the others. Without traceable records, a shipment can be detained at the border or a claimed credit can be disallowed years later.

Do I need blockchain for traceability?

No. Provenance is fundamentally a graph of who mined, produced, manufactured, and assembled each input, plus the cost and certification data at each node. That can be modeled and audited in a well-designed data system without the operational overhead, cost, and integration friction of a blockchain. We build provenance without that overhead.

How does this relate to UFLPA?

UFLPA and FEOC are independent. A product can pass FEOC but fail UFLPA (for example, non-Chinese-owned but containing Xinjiang polysilicon), or pass UFLPA but fail FEOC (a Chinese-owned Malaysian factory using clean polysilicon). Entities on the UFLPA Entity List are automatically Specified Foreign Entities under the tax rules, so the screening overlaps — but the determinations must be tracked separately.

How far down the supply chain do you track?

To the level the rules require — critical mineral extraction, processing, constituent-material production, component manufacturing (cells, wafers, modules, inverters), assembly, and facility integration. At each stage the system records entity status, country, cost, and the supplier certification supporting it.

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