Crystalline Silicon Photovoltaic Cells: Evaluation of the Effectiveness of Import Relief

The Section 201 safeguard tariffs on crystalline silicon photovoltaic (solar) cells and modules expired on February 6, 2026, and the U.S. International Trade Commission (USITC) has launched an investigation to evaluate whether the relief was effective.

What Are Section 201 Safeguard Tariffs on Solar Products?

Section 201 safeguard tariffs are emergency import restrictions imposed when increased imports cause or threaten serious injury to a domestic industry. In 2018, the Trump administration imposed tariffs on imported crystalline silicon photovoltaic (CSPV) cells and modules—commonly known as solar panels—to protect U.S. manufacturers from a surge of low-cost imports, primarily from Asia.

These tariffs applied regardless of country of origin, starting at 30% in 2018 and declining annually to 15% in the final year. The relief officially terminated on February 6, 2026, and the USITC must now evaluate whether these measures successfully helped the domestic solar manufacturing industry recover [Federal Register, 2026].

What Changed on February 6, 2026?

The tariff relief has expired. This means that the additional Section 201 safeguard duties no longer apply to imports of CSPV products. However, importers should note that other tariffs may still apply, including:

• Normal customs duties under the Harmonized Tariff Schedule (HTS)
• Section 301 tariffs on Chinese goods (if applicable)
• Antidumping and countervailing duties on solar products from specific countries
• Circumvention provisions targeting products transshipped through Southeast Asian countries

The expiration doesn't mean solar imports are tariff-free—it means one layer of additional duties has been removed.

Which Products Are Affected?

The Section 201 investigation and tariff relief covered crystalline silicon photovoltaic cells, whether or not partially or fully assembled into other products. This broad definition includes:

• Solar cells (the basic photovoltaic unit)
• Solar modules/panels (multiple cells assembled together)
• Laminates and partially assembled modules
• Building-integrated photovoltaic products (solar roof tiles, solar windows)
• Off-grid solar products like solar chargers and portable solar generators

The tariffs applied to CSPV products from all countries, though certain developing countries received exemptions, and a 2.5 gigawatt annual exemption applied to bifacial solar panels (until that exemption was removed in 2020).

Key Countries Affected

While Section 201 tariffs applied globally, the countries most impacted by their expiration include:

• China (still subject to separate Section 301 and AD/CVD duties)
• Malaysia (major solar manufacturing hub)
• Vietnam (significant solar panel exporter)
• Thailand (growing solar producer)
• South Korea (technology manufacturer)
• Taiwan (cell and module producer)

Important note: Many solar products from China continue to face antidumping duties of 238.95% to 513.64% and countervailing duties of 15.24% to 275.69%, depending on the manufacturer [USITC historical data]. The Section 201 expiration does not affect these separate trade remedies.

Why the USITC Is Reviewing the Tariff Relief

Under Section 204(d) of the Trade Act of 1974, the USITC must evaluate the effectiveness of any safeguard relief within six months after it terminates. The Commission will assess:

1. Did the tariffs help the domestic solar manufacturing industry?

   • Did U.S. production capacity increase?
   • Did domestic manufacturers become more competitive?
   • How many jobs were created or preserved?

2. Did imports still cause injury despite the tariffs?

   • How did import volumes change during the relief period?
   • What was the price impact on the domestic market?

3. What were the unintended consequences?

   • How did the tariffs affect solar installation companies?
   • Did costs increase for residential and commercial solar projects?
   • Were there supply chain shifts to circumvent the duties?

This review is informational and retrospective—it will not result in new tariffs being imposed. However, the findings could influence future trade policy decisions and provide important data for industry stakeholders.

What Should Solar Importers Do Right Now?

1. Verify Your Current Tariff Obligations

Even with Section 201 expired, you likely still face other duties. You need to:

• Confirm the correct HTS classification for your products (typically 8541.40 for photovoltaic cells)
• Check for active antidumping/countervailing duty orders on your supplier's country and manufacturer
• Determine if Section 301 tariffs apply (if importing Chinese-origin components)
• Review your entry documentation to ensure proper valuation and classification

Action item: Pull your recent customs entries and identify which tariffs you're currently paying. Many importers mistakenly believed Section 201 was their only solar-related duty.

2. Re-Evaluate Your Supply Chain

The expiration may change the economics of your sourcing decisions:

• Malaysian and Vietnamese suppliers may now be more cost-competitive relative to other origins
• Chinese suppliers remain heavily tariffed under AD/CVD and Section 301
• Domestic U.S. suppliers may need to adjust pricing now that import competition faces lower duties

Consider requesting updated quotes from multiple suppliers across different countries to optimize your landed costs.

3. Watch for Potential New Trade Actions

The solar industry remains contentious in U.S. trade policy. Monitor for:

• New petitions for trade remedies from domestic manufacturers
• Circumvention investigations targeting transshipment through third countries
• Legislative proposals for domestic content requirements in renewable energy incentives
• Updates to Section 301 tariffs which could affect solar components

4. Review Your Compliance Procedures

Tariff changes create compliance risk. Ensure your customs broker or internal compliance team:

• Updates HTS classifications in your import management system
• Recalculates landed costs for accurate pricing and inventory valuation
• Files any required protests on previous entries if you believe you overpaid duties
• Maintains proper documentation proving country of origin (especially important given circumvention concerns)

5. Consider Submitting Comments to the USITC

The USITC investigation (No. TA-201-075) will accept public comments and may hold hearings. If you're a solar importer, installer, or manufacturer, you have an opportunity to:

• Share data on how the Section 201 tariffs affected your business
• Provide perspective on market conditions and competition
• Influence future trade policy by participating in the formal record

Check the USITC investigation page for deadlines and submission procedures. Typically, you'll have 30-60 days from the investigation's institution to file initial comments.

Timeline and Key Dates

• February 6, 2026: Section 201 safeguard relief officially terminated
• March 17, 2026: USITC published notice of investigation No. TA-201-075 in the Federal Register
• Approximately Summer 2026: Expected deadline for USITC to complete its evaluation (typically within 6 months of relief termination)
• Ongoing: Monitor for comment periods and hearing dates announced by the USITC

Note: While the USITC conducts its review, the expiration remains in effect. The investigation is backward-looking and will not result in tariffs being reimposed.

How to Calculate Your Actual Solar Import Costs Post-Expiration

Without Section 201 duties, your calculation changes from:

Old formula (before Feb 6, 2026):

• Product value: $10,000
• Normal HTS duty (typically 0% for most solar modules): $0
• Section 201 safeguard (15% in final year): $1,500
• Section 301 (if Chinese origin, 25%): $2,500
• AD/CVD (if applicable, varies widely): varies
• Total duties: $4,000+

New formula (after Feb 6, 2026):

• Product value: $10,000
• Normal HTS duty: $0
• Section 201 safeguard: $0 (expired)
• Section 301 (if Chinese origin, 25%): $2,500
• AD/CVD (if applicable): varies
• Total duties: $2,500+ (Chinese origin) or potentially $0-500 (other origins without AD/CVD)

This represents a significant potential savings, but only if you're not subject to other trade remedies. Many solar importers will still face substantial duties depending on their country of origin and specific supplier.

The Broader Context: U.S. Solar Industry and Trade Policy

The Section 201 case represents one chapter in a decades-long debate over solar trade policy. The domestic solar industry is divided:

• U.S. solar manufacturers (primarily cell and module producers) argue they need protection from low-cost imports to survive and expand
• Solar installers and developers contend that tariffs raise costs, slow renewable energy deployment, and eliminate American jobs in installation and project development

According to industry data, the U.S. installed approximately 32 gigawatts of solar capacity in 2025, with over 70% of panels imported [Solar Energy Industries Association, approximate 2025]. Employment in solar installation far exceeds manufacturing jobs, creating competing interests within the renewable energy sector.

The Biden administration's Inflation Reduction Act (IRA) included substantial tax credits for domestic solar manufacturing, attempting to boost U.S. production without relying solely on import barriers. The interaction between these incentives and trade policy will likely shape the industry's future trajectory.

What This Means for Small and Medium Businesses

If you're a small solar installation company, project developer, or distributor:

Potential benefits:

• Lower landed costs on imported panels (depending on origin)
• More competitive pricing for customer quotes
• Improved project economics for commercial and residential installations

Potential risks:

• Uncertainty about whether new trade actions might be filed
• Complexity in tracking remaining tariff obligations (Section 301, AD/CVD)
• Supply chain volatility as manufacturers and importers adjust to changed trade landscape

Strategic recommendation: Don't assume the tariff environment is stable. The USITC review, ongoing antidumping cases, and political interest in solar manufacturing mean the trade policy landscape could shift rapidly.

How TariffCenter.AI Can Help

Navigating the complex solar tariff landscape requires real-time data and accurate classification. TariffCenter.AI provides:

• Up-to-date tariff rates for solar products by HTS code and country of origin
• AD/CVD lookup tools to identify if your specific manufacturer is subject to antidumping or countervailing duties
• Section 301 exclusion tracking for Chinese-origin solar components
• Landed cost calculations that account for all applicable duties, not just the most visible ones
• Alerts for new trade actions affecting your imported products

Stop guessing about your solar import costs. Sign up for TariffCenter.AI and get immediate clarity on your tariff exposure across all solar products in your supply chain.