IRS Notice 2025-10 Details Clean Fuel Production Credit Guidelines
Key Ideas
  • IRS Notice 2025-10 clarifies guidelines for the Clean Fuel Production Credit under section 45Z of the Internal Revenue Code.
  • The credit is tech-neutral and varies based on fuel type and emissions rate, with a notable $1.00 per gallon credit for fuel produced.
  • Qualifying sales, production criteria, and definitions of 'suitable for use' and 'Qualified Facility' are outlined to help taxpayers understand eligibility.
  • Taxpayers using fuels not covered in the standard model may await further Treasury guidance for provisional emission rate requests.
On January 10, 2025, the Treasury Department and the Internal Revenue Service issued IRS Notice 2025-10 to provide guidance on the Clean Fuel Production Credit under section 45Z of the Internal Revenue Code. This new credit, applicable from January 1, 2025, to December 31, 2027, represents a shift to tech-neutral incentives and considers the well-to-wheel emissions rate of fuels like sustainable aviation fuel (SAF) and highway vehicle fuel. The credit amount, including a significant $1.00 per gallon credit for fuel produced, is determined based on the type of fuel and emissions factor. The Notice also introduced the 45ZCF-GREET model for calculating emissions rates, with provisions for fuels not covered in the model. Clarifications on terms like 'suitable for use' and 'Qualified Facility' were provided to assist taxpayers in meeting eligibility criteria. Understanding qualifying sales, production processes, and facility requirements is crucial for taxpayers seeking to benefit from the Clean Fuel Production Credit.
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