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Commerce issued a preliminary affirmative circumvention determination covering crystalline silicon photovoltaic cells and modules completed in Cambodia, Malaysia, Thailand, and Vietnam using Chinese-origin wafers. Country-wide CVD cash-deposit rates of 12.8%-51.2% apply prospectively, with company-specific certifications available for vertically integrated producers sourcing non-Chinese wafers. The determination follows the 2024 scope inquiry petition from the American Alliance for Solar Manufacturing and adopts a modified substantial-transformation test consistent with the 2023 circumvention framework. The finding stacks with the existing Section 201 safeguard and AD/CVD orders on Chinese cells; utility-scale developers with 2026-2027 PPA commitments are now actively seeking wafer-certification differentials to preserve eligible sourcing.
The preliminary determination follows the 2024 scope inquiry petition from the American Alliance for Solar Manufacturing, which argued that Chinese-origin wafers processed into cells in Southeast Asia retained substantive Chinese origin. Commerce adopted a modified substantial-transformation test consistent with the 2023 circumvention framework.
The determination operates alongside existing Section 201 safeguards and the Antidumping/Countervailing orders on Chinese cells. The two-year Biden-era bifacial module exclusion expired in June 2025, so the circumvention finding now applies to the full modules universe. Developers are negotiating Section 232 steel-pass-through offsets with wafer-certification differentials.