The IRS and the Department of Treasury (the Treasury) have announced that they intend to propose regulations to implement the product identification number (PIN) requirement with respect to the energy efficient home improvement credit under Code Sec. 25C as amended by the Inflation Reduction Act of 2022 (IRA) (P. L. 117-169). The IRS has also requested comments on the PIN requirement under Code Sec. 25C(h) (PIN requirement) by February 27, 2024.

Energy Efficient Home Improvement Credit

Beginning January 1, 2023, the energy efficient home improvement credit allows for a credit, subject to certain limitations and caps, equal to 30-percent of the total amount paid by the taxpayer for certain qualified expenditures, including:

  • Qualified energy efficiency improvements installed during the year,
  • Residential energy property expenditures during the year, and
  • Home energy audits during the year.

The credit is allowed for qualifying property placed in service on or after January 1, 2023, and before January 1, 2033. Beginning on January 1, 2025, taxpayers claiming the credit must also satisfy the PIN requirement for certain categories of products. Under this requirement, an item will only qualify for the energy efficient home improvement credit if the item is produced by a qualified manufacturer, and if the taxpayer includes the qualified PIN of the item on their tax return.

Request for Comments

The IRS has requested comments on a number of general and specific questions relating to this PIN requirement and has also outlined a PIN assignment system that the Service is considering. Any comments received will assist in the development of the proposed regulations to implement the PIN requirement. Written comments should be submitted by February 27, 2024. However, consideration will be given to any written comment received after February 27, 2024, if the consideration will not delay the issuance of guidance.

Comments may be submitted in one of two ways:

  • Electronically via the Federal eRulemaking Portal at (type IRS-2024-13 in the search field on the homepage to find this notice and submit comments); and
  • by mail to: Internal Revenue Service, CC:PA:LPD:PR (Notice 2024-13), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044