It’s been a whirlwind summer for the solar industry so far in 2025. The One Big Beautiful Bill (OBBB) accelerated the investment tax credit (ITC) phase-out, and the Treasury Department released new guidance significantly altering safe harbor qualifications. Buried amidst this regulatory turbulence, the 2025 Kiwa PV Evolution Labs (PVEL) Module Reliability Scorecard revealed a disturbing trend about module failure rates. As developers and EPC firms race to secure modules before the deadline, it’s crucial that quality concerns, additional scrutiny, and due diligence during procurement remain a top priority.

Let’s unpack this flurry of policy changes and explore why sticking with long-term reliability over short-term savings is the strategy for success.

Key Solar Takeaways from OBBB and Updated Safe Harbor Rules

Under the Inflation Reduction Act (IRA), developers had until at least 2032 to commence construction to secure tax credits. Following the bill’s passing, an Executive Order directed the Treasury Department to draft new guidance, which it released on August 15 and goes into effect on September 2, 2025.

Expedited Safe Harbor Deadlines: The OBBB dramatically compressed the safe harbor timeline and set a July 2026 deadline, without a slow phase-down. For developers and EPCs holding products under the old rules, construction must be “placed in service” or reach a construction milestone (see next highlight) by July 2026 to retain grandfathered eligibility.

Stricter Qualifying Criteria: For solar projects larger than 1.5MW, the previous rule of incurring 5% of total project costs no longer works to secure safe harbor for ITC eligibility. Instead, developers must now demonstrate that “physical work of a significant nature” has started before the safe harbor deadline. This is a significant departure from prior rules that allowed simply incurring costs on equipment as a qualifier.

Definition of “Physical Work of a Significant Nature”: The guidance clarifies that physical work means on-site activities like starting foundation work, installing racking, or trenching for electrical infrastructure. Notably, the guidance excludes pre-project steps like land grading, conducting studies, and site clearing from the definition of physical work. Off-site manufacturing may count as part of the significant work, but only if the work relates specifically to unique, project-specific components. Generic material purchases or ordinary procurement do not qualify.

Itemized Documentation: This isn’t anything new, but it’s an important reminder that developers must provide detailed documentation to substantiate that qualifying physical work commenced by the deadline. This includes contracts, invoices, photographs, and construction logs confirming actual site activity.

Curtailment of “Warehousing” Approach: The previous practice of warehousing modules or other equipment to satisfy the 5% test is now largely off the table for most larger projects. Buying and storing equipment in itself will not secure the ITC since actual construction progress is now required.

Bottom Line: These stricter rules are pushing all parties in the solar value chain to move fast and demonstrate meaningful site advancement before key deadlines.

Identifying Top-Performing PV Modules as Failures Mount

This shift from financial commitment to actual construction progress has shrunk availability windows from weeks to days as demand surges, creating the perfect conditions for time- and budget-crunched EPCs to consider cutting corners on quality or securing equipment without rigorous due diligence.

Since modules typically represent 30-35% of total project CAPEX, they make a tempting target for cost reduction. Although cheaper modules might help meet initial budget targets and safe harbor requirements, this route does not account for the total cost of ownership over a 25-30 year operational period. The long-term costs of poor reliability far outweigh the upfront savings.

However, procuring durable and low-degradation modules to deliver optimized performance over the system’s lifetime becomes particularly risky in light of the findings in the 2025 Kiwa PVEL Module Reliability Scorecard that module failures are on the rise.

The Scorecard’s results showed that 40% of original equipment manufacturers (OEMs) experienced at least one failure during Mechanical Stress Sequence (MSS) testing, 32% failed during Thermal Cycling (TC) testing (up from 20% for the 2024 Scorecard), and 9% failed Damp Heat (DH) testing.

This rising failure trend has accelerated the adoption of N-type TOPCon module technology, like Trinasolar’s Vertex N, a 2025 “Top Performer” in the Kiwa PVEL Reliability Scorecard. Vertex N excelled in testing for Thermal Cycling (TC), Damp Heat (DH), Mechanical Stress (MSS), and LiD+LeTiD. Vertex N has transitioned from premium upgrades to standard specifications in many community solar projects. For EPCs managing 30-year project lifecycles, Vertex N delivers additional value through reduced degradation rates and lower failure risks.

Trinasolar’s innovative technology improves several critical features that enhance the durability and reliability of Vertex N. These include non-destructive cutting to minimize micro-cracking, and cell-process and module-material controls to ensure resistance to Potential Induced Degradation (PID), giving Vertex N the lowest guaranteed first-year and annual degradation rates. Additionally, advanced multi-busbar technology improves light-trapping effect and current collection, while lowering the series resistance.

The module’s excellent performance in low irradiation and harsh environments, with a mechanical performance up to +5400/-2400 Pa, as well as a lower temperature coefficient (-0.29%/°C) and operating temperature. Widespread compatibility with existing mainstream system components mitigates interoperability risks during installation.

Along with the proven reliability, Vertex N has 620W maximum power output, 23% maximum efficiency, up to 30% additional backside power gain, and high-density interconnection that improves power density. The module’s unique design also provides optimized energy production under inter-row shading conditions.

Bottom line: Trinasolar’s Vertex N modules excel in reliability testing, reduce BOS costs, and lower levelized cost of energy (LCOE), making them the perfect candidate when procuring high-quality, high-performance PV modules.

Future-Proofing Solar Strategies Beyond Safe Harboring

The new market conditions will strain smaller solar EPC firms and solar companies without large procurement teams, especially those without a dedicated procurement team. Beyond the push to procure high-quality modules on an expedited timeline, successful developers and EPCs are developing relationships with suppliers that offer more than just competitive pricing. This long-term partnership approach becomes particularly valuable to avoid quality issues.

Suppliers with strong engineering teams, technical support, and warranty backing, like Trinasolar US, can help with pre-engineering analysis and design, recommend installation best practices, and work collaboratively to address any field performance concerns. On the other hand, price-focused suppliers often provide little technical support (if any at all) and lack the resources and history of bankability to address warranty claims effectively.

With regulatory pressures intensifying and module failure rates at record highs, the cost of poor quality has never been higher. While safe harbor compliance is essential for securing tax credits, module reliability remains critical for long-term profitability.

This article is provided for informational purposes only and is not intended to constitute legal or financial advice. Government policies and regulatory guidance are subject to change and may affect individual projects differently. Developers and EPCs should consult with qualified legal, financial, and tax professionals for advice specific to their circumstances.

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