Census trade data through June 30, 2026; legal text verified August 26, 2026
Executive Order 14420 does not itself prohibit any identified equipment, vendor, country or transaction. It authorizes a prohibition only after the Secretary of Energy finds both covered-entity involvement and a specified risk. For the one listed equipment class whose imports are directly measurable, Census reports the over-100,000 kVA transformer count rising from 617 units in 2019 to 2,268 in 2025. Those imports had diverse reported origins, including Mexico and several U.S. allies and partners; China was 2.2% of units in 2025 and no more than 7.4% in any year from 2019 through 2025. Country of origin is not covered-entity status, and these figures cannot locate the risk the order asks DOE to assess.
Four different questions stay separate on this page. The order defines legal scope. Commerce and DOE provide a one-year manufacturing estimate. Census measures imports for two customs categories. Agency reports and advisories describe equipment and software that customs data cannot isolate. None of those sources supplies a current domestic-production denominator for a single all-equipment measure.
In plain language, it is the interconnected generation, high-voltage transmission and control network used to move electricity over long distances and keep the larger system reliable. It is not the same thing as every wire, transformer or digital device connected to electricity.
| Definition | What it says | Why it matters here |
|---|---|---|
| Statutory Bulk-Power System | Federal Power Act section 215 covers facilities and control systems needed to operate an interconnected transmission network, plus generation needed for transmission reliability. It excludes local distribution. | The statute does not set a voltage threshold. |
| NERC Bulk Electric System | The NERC reliability definition generally starts with elements operated at 100 kV or higher, then applies stated inclusions and exclusions. | This is the familiar reliability-registration boundary, not the order's 69 kV language. |
| EO 14420 bulk-power system | The order repeats the statutory structure, excludes local distribution facilities, and says its definition includes transmission lines rated 69 kV or more. | The 69 kV language applies to transmission lines. It is not a universal cutoff for every component inside a covered substation, generating station or control system. |
Sources: 16 U.S.C. 824o(a)(1); FERC Order No. 773 on NERC's Bulk Electric System definition; and EO 14420, section 5.
August 26, 2026 is a transaction-date cutoff: section 2 reaches a covered transaction initiated after the order's date. It is not the effective date of a general import ban. A prohibition attaches only when DOE makes both required findings about covered-entity involvement and risk.
| Provision | What it requires or permits | Who decides | When | Type |
|---|---|---|---|---|
| Section 2(a) | Prohibits a post-order transaction only after findings that covered equipment or an associated component, software, service or remote-access capability involves a Covered Foreign Entity and presents one of the stated undue or unacceptable risks. | Secretary of Energy, with the stated coordination and consultation | Transactions initiated after August 26, 2026; no finding date set | Conditional prohibition after a determination |
| Section 2(b) | Permits conditions on continued use, operation or maintenance of pre-existing foreign-manufactured or operated equipment, including identification, monitoring, isolation, disconnection, replacement or removal. | Secretary of Energy after the section 2(a) findings | No fixed date | Discretionary step |
| Sections 2(c) and 2(e) | Permits negotiated mitigation and criteria or lists for pre-qualified equipment and vendors. Qualification does not remove DOE's later authority. | Secretary of Energy | No fixed date | Discretionary step |
| Section 3(b) | Directs publication of implementing rules or regulations as needed. Rules may address covered entities, scrutiny and licenses. | Secretary of Energy after stated consultation | Within 120 days | Qualified fixed-date duty |
| Section 3(c) | Directs identification of risky equipment and recommendations to the President on identification, inventory, isolation, monitoring or replacement. | Secretary of Energy after stated consultation | As soon as practicable | Open-ended duty, not a fixed deadline |
| Section 4(a) | Directs recommended FAR revisions addressing security and U.S.-made infrastructure. | Secretary of Energy | Within 180 days | Fixed-date recommendation |
| Section 4(b) | Requires the FAR Council to consider proposing amendments for notice and comment. It does not require a final procurement rule. | FAR Council | Within 90 days of receiving DOE's recommendations | Fixed-date duty to consider a proposal |
| Section 6 | Directs recurring and final national-emergency reports to Congress. | Secretary of Energy | No fixed date in the order | Open-ended reporting duty |
The definition has two tracks. First, it incorporates by reference a foreign country subject to a U.S. arms embargo or sanctions regime under 22 C.F.R. 126.1, along with covered ownership, control or jurisdiction relationships. Second, DOE may, after the specified consultation, determine that another country or person is engaged in conduct detrimental to U.S. national security or foreign policy. The order itself does not publish a new country list.
Four attributes must not be collapsed: where an article was made, who owns or controls a company, who holds an interest in a transaction or contract, and who created or operates software, firmware, services or remote access. The order defines “foreign-produced” only as not manufactured, produced or assembled in the United States.
Section 2(b) addresses equipment acquired or installed before August 26. After the section 2(a) findings, DOE may require monitoring, isolation, security measures, disconnection, replacement or removal. Before directing isolation, disconnection, replacement or removal, DOE must consider reliability and safety, secure replacement availability, and continuity of essential service; it may phase compliance. That is different from the rule for a new transaction.
This history is an analogy, not a forecast of EO 14420's scope. EO 13920 was signed May 1, 2020. DOE's December 17 implementing order was narrow: it applied to a limited set of utilities serving critical defense facilities and specified bulk-power equipment from the People's Republic of China, with a January 16, 2021 effective date. On January 20, EO 13990 suspended EO 13920 for 90 days, which also suspended the implementing order and its certification dates. DOE revoked that prohibition order effective April 20, 2021, before the underlying emergency declaration expired on May 1.
Sources: EO 13920; DOE's prohibition order; EO 13990; and DOE's April 20 revocation.
DOE's defined 2019 estimate: for large power transformers defined as 100 MVA or larger, DOE reports Commerce's 2019 estimate of 617 imported units and 137 units produced domestically for domestic use, making imports 82% of apparent consumption that year. Commerce identifies the import series as liquid dielectric transformers over 100,000 kVA; our Census edition reproduces its 617-unit numerator exactly.
The same Census line reports 2,268 units and $2,774 million of nominal customs value in 2025. That is a change in the reported import count, not a current import percentage. The 137-unit domestic figure has no compatible updating series here.
| Year | Transformer units | Transformer customs value, nominal $M | GOES metric tons | GOES customs value, nominal $M |
|---|---|---|---|---|
| 2013 | 504 | $682.1 | 30,962 | $83.1 |
| 2014 | 568 | $736.1 | 18,800 | $44.2 |
| 2015 | 681 | $821.1 | 27,311 | $66.9 |
| 2016 | 576 | $767.4 | 33,894 | $77.0 |
| 2017 | 520 | $610.0 | 67,083 | $146.2 |
| 2018 | 505 | $565.3 | 58,572 | $116.3 |
| 2019 | 617 | $619.7 | 26,763 | $50.7 |
| 2020 | 729 | $715.5 | 26,218 | $50.8 |
| 2021 | 539 | $717.9 | 41,836 | $89.1 |
| 2022 | 771 | $827.1 | 19,951 | $67.4 |
| 2023 | 1,372 | $1,300.6 | 31,415 | $125.0 |
| 2024 | 1,806 | $2,074.4 | 35,174 | $115.8 |
| 2025 | 2,268 | $2,774.3 | 19,821 | $63.8 |
For the transformer line, the top reported origin supplied 16.8% of customs value and the top three supplied 49.6%. For GOES the corresponding shares were 59.6% and 86.1%. These are the two concentration measures used here; the page does not assign a broader concentration label.
| Transformer origin | Units | Nominal customs value | Value share | Unit share |
|---|---|---|---|---|
| KOREA, SOUTH | 323 | $466,421,733 | 16.8% | 14.2% |
| BRAZIL | 343 | $462,440,800 | 16.7% | 15.1% |
| MEXICO | 630 | $446,950,752 | 16.1% | 27.8% |
| AUSTRIA | 124 | $300,955,279 | 10.8% | 5.5% |
| NETHERLANDS | 172 | $255,580,775 | 9.2% | 7.6% |
| TAIWAN | 167 | $140,353,640 | 5.1% | 7.4% |
| CANADA | 84 | $120,978,832 | 4.4% | 3.7% |
| CROATIA | 33 | $80,544,107 | 2.9% | 1.5% |
| COLOMBIA | 68 | $69,617,799 | 2.5% | 3.0% |
| TURKEY | 42 | $69,031,907 | 2.5% | 1.9% |
Interpretation limit next to the China figure: customs origin records where an imported article was produced under trade rules. It does not establish supplier ownership or control, component origin, firmware authorship, a maintenance provider, a remote-access operator, or transshipment risk. A small China origin share therefore does not show where covered-entity risk is concentrated. That remains unresolved.
Basis. The edition uses Census monthly imports for consumption at HS10 detail level.
Published value is CON_VAL_MO, the nominal customs value. CIF value is fetched and retained
but is not displayed. Quantity is CON_QY1_MO: units for 8504230080 and kilograms for the four
GOES lines. Country means country of origin.
Completeness. Every code-month must include Census's all-countries row, whose country
code is -, and the sum of country detail must reconcile to it within 0.5%. Missing months,
duplicate keys, unit or description changes, and HTML block pages stop publication. A zero-valued row
is retained as a true zero; an absent code-month is a failure.
Customs-to-equipment mismatch. The transformer line is strictly over 100,000 kVA, while DOE describes LPTs as 100 MVA or larger. A unit exactly at 100 MVA falls in 8504230045, not the published 8504230080 line. The measured line also cannot identify installation voltage or end use. The GOES series combines only the four grain-oriented steel lines and is outside the order.
Missing denominator. Census measures imports, not compatible domestic production or total U.S. demand. The page therefore reports value, quantity and defined origin shares. It does not calculate a current import-penetration rate or a single measure of foreign dependence. Annual totals are lumpy: a few large deliveries, product mix and price changes can move value or count.
DOE's July 2024 resilience report calls limited cost-effective domestic LPT manufacturing capacity a significant weak link. It repeats Commerce's 2019 estimate and explains that multi-product build slots and one-to-three-year factory construction make capacity difficult to expand quickly.
The same DOE report says about 80% of U.S. GOES demand was imported in 2019 and that the sole U.S. producer could meet about 12% to 20% of domestic demand. GOES is discussed as a transformer input, not as regulated equipment.
Sources: Commerce Section 232 transformer and GOES report and DOE Large Power Transformer Resilience Report to Congress, July 2024.
This section contains sourced editorial evidence only. It has no computed import series.
DOE CESER's January 2025 BESS supply-chain assessment treats foreign-manufactured BESS components, inverter-based resources and transformers together and recommends mitigations for installed, planned and future systems. DOE's 2022 storage assessment separately documents concentration in lithium-ion materials and subcomponents. Neither report turns the broad battery or static-converter tariff codes into a grid-only import series.
CISA's November 2024 PowerLogic P5 advisory documents a specific relay vulnerability that could permit reboot, denial of service or full control with physical access. It is product-specific evidence about digital exposure, not evidence about the prevalence or origin of all relays.
CRS R48933 reports strained recent supply, longer order times and limited manufacturing information for distribution transformers. These devices serve local distribution and are not computed from transformer HS codes here. The order expressly excludes local distribution facilities.
DOE's 2020 Smart Grid System Report explains that modern ICS devices increasingly use ordinary networking and remote-access paths. CISA's remote access guidance treats secure vendor access, monitoring and network separation as control-system design questions. Those attributes are not visible in country-of-origin customs records.
Sources: DOE CESER BESS assessment; DOE Grid Energy Storage Supply Chain Deep Dive; CISA PowerLogic P5 advisory; CRS R48933; DOE Smart Grid System Report; and CISA remote-access guidance.
“Listed” below means only that the item appears in the order's equipment definition. A transaction still requires the section 2 findings before it is prohibited. The columns are independent: an item can be listed, impossible to isolate in trade data, and retained as a named evidence gap.
| Equipment or attribute | EO status | Trade observability | V1 treatment | Source | Limitation |
|---|---|---|---|---|---|
| Reactors | Listed in definition | Not observable | Named as a gap | EO 14420 | Customs data do not identify bulk-system use. |
| Capacitors | Listed in definition | Not observable | Named as a gap | EO 14420 | Broad product and end-use scope. |
| Substation transformers | Listed in definition | LPT subset isolable | Computed series for 8504230080 only | Census; Commerce; DOE | Line cannot identify installation voltage or end use. |
| Grid-connected inverters | Listed in definition | Observable but contaminated | Sourced editorial | DOE CESER BESS report | Static-converter codes are dominated by broader uses. |
| Battery energy storage systems | Listed in definition | Observable but contaminated | Sourced editorial | DOE storage reports | Battery codes include vehicles and consumer cells. |
| Critical-infrastructure UPS | Listed in definition | Not observable | Named as a gap | EO 14420 | Critical-infrastructure use is not a customs field. |
| Current coupling capacitors | Listed in definition | Not observable | Named as a gap | EO 14420 | No validated grid-only line. |
| Large generators | Listed in definition | Not observable | Named as a gap | EO 14420 | Capacity and covered use cannot be isolated. |
| Small generators | Listed in definition | Not observable | Named as a gap | EO 14420 | Covered use cannot be isolated. |
| Backup generators | Listed in definition | Not observable | Named as a gap | EO 14420 | Backup role is not a customs field. |
| Substation voltage regulators | Listed in definition | Not observable | Named as a gap | EO 14420 | No validated grid-only line. |
| Shunt capacitor equipment | Listed in definition | Not observable | Named as a gap | EO 14420 | No validated grid-only line. |
| Automatic circuit reclosers | Listed in definition | Not observable | Named as a gap | EO 14420 | Grid voltage and use cannot be isolated. |
| Instrument transformers | Listed in definition | Observable but contaminated | Named as a gap | EO 14420 | Transformer codes classify construction and capacity, not covered use. |
| Coupling capacity voltage transformers | Listed in definition | Not observable | Named as a gap | EO 14420 | No validated grid-only line. |
| Protective relaying | Listed in definition | Not observable | Sourced editorial | CISA PowerLogic P5 advisory | One advisory does not describe the whole market. |
| Metering equipment | Listed in definition | Not observable | Named as a gap | EO 14420 | Bulk-system role is not a customs field. |
| High-voltage circuit breakers | Listed in definition | Observable but contaminated | Named as a gap | EO 14420 | 8535 is deferred until a transmission-class HS10 line is validated. |
| Generation turbines | Listed in definition | Not observable | Named as a gap | EO 14420 | Covered station use is not isolated. |
| Industrial control systems, RTUs, PLCs and IEDs | Listed in definition | Not observable | Named as a gap | DOE Smart Grid report | Hardware function and deployment are not customs fields. |
| Distributed control systems | Listed in definition | Not observable | Named as a gap | EO 14420 | System architecture is not observable. |
| Safety instrumented systems | Listed in definition | Not observable | Named as a gap | EO 14420 | System role is not observable. |
| Software and firmware | May be considered with listed equipment | Not observable | Named as a gap | EO 14420; DOE | Authorship and update control are absent from trade records. |
| Digital and maintenance services | May be considered with listed equipment | Not observable | Named as a gap | EO 14420 | Services are not goods-import observations. |
| Remote-access capabilities | May be considered with listed equipment | Not observable | Named as a gap | CISA guidance | Operator identity and access paths are absent from trade records. |
| Local distribution transformers | Expressly excluded with local distribution facilities | Observable but contaminated | Sourced editorial only | CRS R48933 | No computed series; distribution use is not isolated by the transformer codes. |
| Grain-oriented electrical steel | Outside the order; input to covered transformers | Isolable at four validated HS10 lines | Computed series | Census; DOE | Material imports are not equipment transactions under the order. |
No observation revisions have been recorded since immutable edition tracking began. Future changes create a new edition and remain visible in the cumulative ledger.
See the public data-updates log. The committed edition retains raw Census responses, semantic and file hashes, the year-versioned classification registry, reconciliation results and keyless canonical queries. Ordinary builds use those files offline.
