What CUSMA asks of you
The Canada-United States-Mexico Agreement governs origin and preferential treatment for goods moving across North America. For solar and storage buyers, the practical effect is that origin must be documented at the component level, not asserted at the shipment level.
Official text and guidance are published by Global Affairs Canada, and buyers should reference the current agreement text rather than summaries when drafting contract language.
What FEOC and prohibited-foreign-entity rules restrict
Foreign-entity-of-concern provisions restrict incentives and, in some programs, market participation where components or controlling ownership trace to designated entities. The test is about control and provenance, not just the shipping address.
Because ownership structures change, compliance is a continuing obligation. Contracts should require notice of any change in control that would affect status.
The documentation package to require
A supplier that cannot produce this package quickly is telling you something useful.
- Component-level bill of materials with country of origin for cells, glass, frames and modules.
- Ownership and control disclosure for the manufacturing entity and its parents.
- Certificates of origin aligned to the CUSMA rules applicable to the tariff classification.
- A contractual representation that survives closing, with notice obligations on any change.
Why domestic manufacturing simplifies all of it
A North American manufacturing base with transparent ownership turns compliance from an investigation into a disclosure. That is the structural reason the Chatham-Kent campus integrates cell-to-module and cell-to-pack production inside Canada.