US Export Plan - Sector Report- Renewables

Trade, policy and regulation considerations

Exporters of renewable energy products and services to the United States must navigate a range of regulatory and compliance requirements, depending on the nature of what they are selling. Furthermore, exporters should be aware of tariffs and duties that may apply to products and components. Accurate product classification and recordkeeping are essential to ensure full compliance with US trade laws.

The mix of federal and state level regulations vary by subsector, and can be complex and fragmented. For example, the regulatory framework for hydrogen involves numerous government agencies and a mix of federal, state, and local rules. Certain states are authorised to assume permitting responsibilities for programmes administered by the EPA, including the National Pollutant Discharge Elimination System (under the Clean Water Act), the Clean Air Act, and Class VI Underground Injection Control (UIC) (under the Safe Drinking Water Act). For blue hydrogen projects, the EPA may grant states primacy under the Class VI UIC program; currently six states have approval (Texas, Arizona, West Virginia, North Dakota, Wyoming and Louisiana). However, it should be noted that the EPA has undergone considerable reductions in its remit and power under the current administration so there is uncertainty over its role in future permitting. States and local jurisdictions may also have wetland permitting requirements in addition to the federal CWA Section 404 dredge and fill program. ^[39]

There will also be specific requirements for specific projects. For example, a consideration for offshore wind is that state governments leading on the procurement for projects often attach economic benefit of content requirements to their tenders, which can require establishing a presence in the United States, or a joint venture^[40].

Policy shifts in 2025

Prior to 2025, US federal policy strongly favoured renewable energy, driven by the Inflation Reduction Act (IRA) and ambitious net-zero targets, which spurred record solar and battery storage deployment and significant investment in clean energy manufacturing. However, since mid-2025, a series of federal actions have introduced some uncertainty around renewable energy development. That said, it is important to recognise that policy frameworks are dynamic and subject to change; therefore, any exporters looking to enter the US will need to regularly review for updates.

While before 2025 tax credits had been extended for wind, solar and hydrogen through to 2032, wind and solar credits are now set to end by 2027, with stricter eligibility criteria. This means offshore wind exports face compressed timelines; and exporters will need to prioritise advisory roles and state-level projects.

Likewise, pre-2025 domestic content rules were more flexible, but compliance and foreign entity restrictions have been increased through 2025 meaning more limited international supply chain access, potentially driving Scottish firms to need to partner with US manufacturers or establish a local presence.

Technology-wise, there has been a notable shift towards fossil fuels, advanced nuclear and grid resilience. Whilst support for wind, solar and green hydrogen has markedly reduced, there has been some growing support for geothermal and blue hydrogen. This presents opportunities in geothermal drilling, grid resilience solutions and advanced hydrogen systems among other areas.

Opportunities amid constraints

While there are some changes in the federal-level picture, many US states continue to pursue ambitious clean energy goals. Renewable Portfolio Standards (RPS) and Clean Energy Standards (CES) remain in place across numerous states. These mandates require utilities to source a defined percentage of their electricity from renewable sources.

Exporters may find strategic opportunities by aligning with states that have the most ambitious clean energy targets, forming partnerships with US utilities, developers, and manufacturers, and leveraging expertise in areas such as offshore wind, hydrogen electrolysis and grid integration.

Examples of these measures in some key states include:

• California: 60% renewable by 2030, 100% clean electricity by 2045
• Maine: 80% renewable by 2030, 100% clean electricity by 2040
• Minnesota: 55% renewable by 2050, carbon-free electricity by 2040
• Massachusetts: 100% carbon-free by 2040
• Illinois: 100% clean by 2050
• New York: 70% renewable by 2030, 100% carbon-free electricity by 2040
• Vermont: 100% renewable by 2035
• Washington: 100% renewable or zero-emitting by 2045

Memorandums of Understanding

Certain export opportunities may be strengthened or supported by Memorandums of Understanding (MoU) between the UK and specific states, many of which emphasise collaboration in energy sectors. These include:

• California: The Under2 MoU between California and Scotland is a climate agreement where both subnational governments committed to bold action, sharing best practices on reducing emissions, expanding renewables (like offshore wind), and influencing global climate ambition. Further ratification came in Feb 2026 through the signing of a new UK-California MoU with shared objectives in relation to addressing climate change, promoting sustainable development, protecting the natural environment and promoting responsible innovation.
• Colorado (signed 27 January 2025): The UK MoU prioritises co-operation in clean energy and low emissions technology^[41]
• Illinois (signed 8 April 2025): The UK MoU prioritises cooperation in renewable energy and zero and low emissions technology, including wind energy, zero emissions vehicles, Small Modular Reactors, hydrogen, and related infrastructure and regulatory frameworks.
• Oregon (signed 5 November 2025): The UK MoU prioritises cooperation on clean energy and green technology, including decarbonisation, wind energy, zero emissions vehicles, hydrogen, related infrastructure and regulatory frameworks.
• Texas (signed 13 March 2024): This Statement of Mutual Cooperation specifies 9 priority areas for bilateral cooperation, including emerging energy solutions.