Solar import duties on four countries reset where panels get sourced
Preliminary antidumping and countervailing duties on solar cells from Cambodia, Malaysia, Thailand, and Vietnam took effect in December, on top of existing Section 201 tariffs. Procurement teams had already started moving before the final determination followed months later.
December 2024 · North America
Retrospective analysis of December 2024. Published August 2026.
The US Department of Commerce's preliminary antidumping determination on crystalline silicon photovoltaic cells from Cambodia, Malaysia, Thailand, and Vietnam took effect 4 December 2024, applying duties to solar cell imports from those countries on top of the existing Section 201 tariffs already in place on imported panels generally. Commerce had opened the investigation in May 2024 after US manufacturers alleged the four countries were being used to route Chinese-linked production around existing China specific duties, and preliminary countervailing duties had already been placed on companies in all four countries that fall. Commerce's final affirmative determination followed on 21 April 2025, confirming that imports from all four countries were being dumped and had received countervailable subsidies, in several cases traced to transnational subsidies from the Chinese government.
The Signal
Commerce's preliminary antidumping determination on solar cells from Cambodia, Malaysia, Thailand, and Vietnam took effect 4 December 2024, layering onto existing Section 201 tariffs, with a final affirmative determination following 21 April 2025 that found transnational subsidies traced to China in several cases.
Why It Matters
A preliminary determination changes procurement economics well before the final ruling lands, since duty liability typically applies retroactively to the preliminary determination date. Developers and EPC contractors sourcing from these four countries were exposed to duty risk on shipments from early December 2024 forward, months before the final rate was actually known.
Capital Implication
Projects with module supply contracts signed against these four countries before December 2024 needed to reassess landed cost assumptions immediately, not wait for the April 2025 final determination, since the financial exposure was already live.
Development Implication
Procurement teams that had already diversified sourcing beyond the four named countries before the preliminary determination absorbed materially less disruption than those that had concentrated supply chains there, a diligence question worth asking on any project financed in this window.
What We Are Watching
- Sourcing shifts to countries not named in this determination, and whether Commerce opens further country specific investigations.
- The Section 201 tariff's own scheduled expiration in February 2026 and whether that changes the net duty picture.
- Module pricing data as the market absorbs the final determination's confirmed rates.
