of this paragraph, all persons which are treated as a single employer under subsections (a) and (b) of section 52 shall be treated as a single taxpayer. (2) Qualifying infant formula manufacturing project The term qualifying infant formula manufacturing project means a project, any portion of the qualified investment of which is certified by the Secretary under subsection (d) as eligible for a credit under this section, which re-equips, expands, or establishes a facility for the manufacture of eligible infant formula. (3) Eligible property The term eligible property means any property— (A) which is necessary for the manufacture of eligible infant formula, (B) which is— (i) tangible personal property, or (ii) other tangible property (not including a building or its structural components), but only if such property is used as an integral part of a facility described in paragraph (2), and (C) with respect to which depreciation (or amortization in lieu of depreciation) is allowable. (4) Eligible infant formula The term eligible infant formula means infant formula that— (A) may lawfully be sold in the United States, and (B) is manufactured in the United States. (d) Certification (1) In general (A) Establishment Not later than 180 days after the date of the enactment of this section, the Secretary shall establish a qualifying infant formula manufacturing project program to consider and award certifications for qualified investments eligible for credits under this section to qualifying infant formula manufacturing projects. (B) Application period Each applicant for certification under this paragraph shall submit an application— (i) certifying that not less than 50 percent of the eligible infant formula manufactured using the eligible property to which such application relates during the 1-year period beginning on the date on which the qualifying infant formula manufacturing project is placed in service shall be sold for use in the United States, and (ii) containing such information as the Secretary shall require. (C)