On August 26, 2026, President Trump signed Executive Order 14421, invoking the International Emergency Economic Powers Act and National Emergencies Act to address foreign-produced equipment in the U.S. bulk-power system.
The order declares that foreign-produced bulk-power equipment poses an “unusual and extraordinary threat” to national security, foreign policy, and the broader American economy.
The administration cited rapid growth in artificial intelligence, data centres, advanced manufacturing, and defence production as key drivers behind the threat assessment informing the executive order.
Under the order, any transaction involving property in which a foreign country or national has an interest is subject to prohibition, with the measure applying retroactively to August 26, 2026.
The Department of Energy must determine that equipment is tied to a Covered Foreign Entity and that the transaction poses an undue risk of sabotage, unauthorised access, or supply disruption before a prohibition takes effect.
Transactions may also be blocked where DOE finds an undue risk of catastrophic effects on critical infrastructure, the economy, or an otherwise unacceptable risk to national security.
According to analysis by Jason A. Lewis and Scott H. Segal of Bracewell LLP, the order goes well beyond a simple prohibition on Chinese transformers or solar inverters, establishing the architecture for a federal trusted supply chain.
The supply chain framework extends from physical equipment through software, firmware, servicing, and remote access, representing one of the most comprehensive federal interventions in grid security to date.
The DOE is required to publish implementing rules by December 24, 2026, in consultation with other senior executive branch officials, with those rules expected to clarify which countries, companies, and equipment are covered.
Lewis and Segal noted that DOE’s implementing rules will need to strengthen grid security without exacerbating equipment shortages or delaying the installation of needed capacity.
On September 9, 2026, DOE’s Office of Cybersecurity, Energy Security, and Emergency Response published a Request for Information seeking input from utilities, manufacturers, software providers, EPC firms, investors, and insurers, among others.
The request for information is intended to inform the forthcoming implementing regulations, with public comments due within 30 days of the document’s publication.
A public webinar is scheduled for September 16, 2026, giving stakeholders an opportunity to engage directly with the process before the comment period closes.