Trump’s Grid Equipment Order Names Inverters, Batteries and Transformers But Bans Nothing Yet
- FERC & Federal Policy & Markets Power Electronics Regulatory
Marin Holt
- 0
- 9 minutes read
- Executive order: Executive Order 14420, signed August 26
- DOE rulemaking deadline: 120 days
- Countries in scope: 24 ITAR arms-embargo and sanctioned countries
- Transmission threshold: 69 kV and above
- China share of certain grid equipment: 80% or more of world production
President Donald Trump signed Executive Order 14420 on August 26, declaring a national emergency over foreign-made grid hardware. The order reaches substation transformers, utility-scale inverters, battery energy storage systems, high-voltage circuit breakers, protective relaying and industrial control systems across the United States bulk-power system. It applies to transactions started after August 26. No equipment is barred today. The Department of Energy has 120 days, to roughly December 24, to publish the rules that make the order operate. The Edison Electric Institute, whose members plan to invest $1.1 trillion between 2025 and 2029, said utilities will work with DOE on implementation.
What Actually Changed
The order rests on the International Emergency Economic Powers Act and the National Emergencies Act. It bars future transactions in bulk-power system electric equipment on one condition. The Energy Secretary must find that an item ties to a covered foreign entity. The item must also create unacceptable risk of sabotage, remote access or supply disruption. The order defines a covered foreign entity by reference to countries under United States arms embargoes and sanctions in the International Traffic in Arms Regulations. Law firm Norton Rose Fulbright counts 24 such countries. The order itself names none of them.
The equipment list runs long. It covers reactors, capacitors, substation transformers, grid-connected inverters, battery energy storage and uninterruptible power supplies. It also covers voltage regulators, automatic circuit reclosers, instrument transformers, protective relaying, metering, high-voltage circuit breakers and generation turbines. Industrial control systems sit in scope too, down to remote terminal units and programmable logic controllers. Norton Rose Fulbright reads the scope to reach transmission rated at 69 kV and above, plus the generation needed to hold the system together.
What Did Not Change
Local distribution stays outside the order. The White House fact sheet states that the order does not apply to facilities used for local distribution of electric energy. Residential and small commercial assets sitting on low-voltage lines fall outside it.
Nothing already bolted to a substation pad becomes illegal on signature. DOE holds separate authority to set conditions on continued use of installed gear. The order tells the Secretary to weigh reliability, safety, replacement availability and service continuity first. Bridget Bartol runs industry and regulatory affairs at the National Electrical Manufacturers Association. She called the order an update and expansion of Executive Order 13920. That 2020 action aimed at large power transformers from China.
Enforcement Reality
Enforcement waits on rulemaking. DOE has 120 days to publish implementing rules and 180 days to recommend revisions to the Federal Acquisition Regulation. The FAR Council then gets 90 days to consider those amendments. Until DOE evaluates specific vendors and issues risk determinations, Norton Rose Fulbright reads the order as barring no particular product.
The gap that matters is definitional. “There is a need for a lot more clarity around the covered entity concerns,” Bartol told Utility Dive. She pointed at software and digital products as the hardest case. A transformer carries a factory address. Bartol asked what it means for a product to be designed and developed by a covered foreign entity when firmware is written in one country and compiled in another. The order defines foreign-produced as an article not manufactured, produced or assembled in the United States, which sweeps in allied suppliers alongside adversary ones. China accounts for 80% or more of world production of certain grid equipment, including lithium-ion cells.
Why It Matters
A storage or solar developer now tracks a fourth federal lane running over the same hardware. The FCC added foreign-made power inverters to its covered list this month and extended that restriction to wired devices. Foreign Entity of Concern rules, domestic content tests and Section 45X credits already apply. Tariffs already apply. DOE risk determinations now join them, and each lane carries its own definition of a disqualifying foreign tie.
Procurement teams should treat the December rulemaking as the date to plan around, not the signing. The order already applies to transactions started after August 26, and DOE writes the rules that give it teeth. Ask suppliers now for country of manufacture, country of assembly and the origin of any firmware. Get the answers in writing, before a rule exists to force the question.
Critical Perspective
DOE has 120 days to publish the rules, which puts the first binding text near December 24, and until then the order names no vendor and bars no product. NEMA calls this an update and expansion of Executive Order 13920, but 13920 covered large power transformers from China while this list runs from reactors to programmable logic controllers. The Edison Electric Institute’s members plan to invest $1.1 trillion between 2025 and 2029, and they will place most of those orders before the rules exist. If foreign-produced means anything not assembled in the United States, what happens to a substation transformer built in Canada or South Korea by a supplier nobody calls an adversary?
Sources
- The White House, Declaring a National Emergency to Secure the United States Bulk-Power System (Aug 26, 2026)
- The White House, Fact Sheet: Declaring a National Emergency to Secure America’s Bulk-Power System
- Utility Dive, Trump declares emergency, moves to block some foreign-made equipment from grid (Aug 27, 2026)
- pv magazine USA, Executive order bans foreign-produced transformers, inverters, and circuit breakers for U.S. power grid (Aug 27, 2026)
- ESS News, US bans Chinese-made battery energy storage in new Trump directive (Aug 27, 2026)
