The United States has announced a new trade measure covering imported polysilicon and selected downstream products used in the semiconductor and solar photovoltaic industries.
On August 6, 2026, President Donald Trump signed a proclamation under Section 232 of the Trade Expansion Act of 1962. The new framework combines minimum import prices with additional tariffs on covered products.
The measures will take effect at 12:01 a.m. Eastern Time on December 4, 2026.
For importers, exporters and solar supply-chain companies, the new rules could significantly affect customs valuation, landed costs, documentation requirements and shipping arrangements.
What Products Are Covered?
The proclamation covers polysilicon and several downstream products made from polysilicon, including:
- Polysilicon
- Polysilicon ingots
- Silicon wafers
- Solar cells
- Solar modules
The exact scope of the policy is determined by the HTSUS classifications and product descriptions listed in the proclamation’s annexes.
Importers should not rely only on general commercial product names. The applicable HTSUS code, product specifications and country of origin should be reviewed before shipment.
New Minimum Import Prices
The proclamation establishes the following minimum import prices:
- Polysilicon: US$21 per kilogram
- Polysilicon ingots and wafers: US$100 per kilogram
- Solar cells: US$0.22 per watt
- Solar modules: US$0.38 per watt
These price floors will apply to covered goods entered for consumption, or withdrawn from a U.S. warehouse for consumption, on or after December 4, 2026.
If the declared value is lower than the applicable minimum import price, the importer may be required to pay a specific tariff equal to the difference between the entered value and the minimum import price.
For example, if a covered solar module is entered at a value below US$0.38 per watt, a tariff may be imposed to cover the difference between the declared value and the applicable price floor.
Documentation Requirements for U.S. Importers
U.S. Customs and Border Protection will allow importers to submit documentation demonstrating or certifying that the first arm’s-length sale of the imported goods in the United States will take place at or above the applicable minimum import price.
The proclamation also provides rules for certain fixed-term contracts signed before the proclamation was issued.
If the importer does not submit the required documentation, the imported goods may be subject to a specific tariff equal to the full applicable minimum import price—not merely the difference between the declared value and the price floor.
CBP will monitor the accuracy of the documents and certifications submitted by importers.
If CBP determines that the information is materially inaccurate or that the importer has failed to comply with its certification, penalties may apply. The importer and its affiliated companies could also be prohibited from importing covered polysilicon products into the United States in the future.
Accurate invoices, contracts, payment records and sales documentation will therefore be essential.
Additional 15% Section 232 Tariff
In addition to the minimum import price program, covered imports of polysilicon ingots and specified downstream products will generally be subject to an additional 15% ad valorem tariff from December 4, 2026.
Depending on the product and its country of origin, this new Section 232 tariff may apply together with:
- Regular U.S. customs duties
- Section 301 tariffs
- Antidumping duties
- Countervailing duties
- Merchandise Processing Fees
- Other applicable customs charges
This means that importers should calculate the complete landed cost rather than considering the new 15% tariff in isolation.
However, the proclamation includes special treatment for covered products originating from Japan, South Korea, Taiwan, Switzerland, Liechtenstein and European Union member states.
For these origins, the additional Section 232 tariff and the applicable HTSUS Column 1 duty rate will generally equal a combined rate of 15%.
Therefore, the rule should not automatically be interpreted as an additional 15% on top of every existing duty for products from all countries.
Increased Monitoring Before the Effective Date
The U.S. government has also directed the Department of Commerce and CBP to monitor unusual increases in imports before the new measures take effect.
This is intended to prevent companies from importing unusually large quantities of covered products before December 4 in order to avoid the new requirements.
Importers planning to accelerate shipments should ensure that the shipment volume, customs value and commercial purpose are supported by normal business records.
Attempts to stockpile goods or artificially adjust shipment timing may attract additional attention from U.S. authorities.
How Could the Policy Affect Solar Importers?
The new measures could increase the landed cost of imported solar products, particularly when the declared value is below the applicable minimum import price.
Importers may also face additional compliance work, including:
- Confirming whether products fall within the covered HTSUS classifications
- Reviewing the country-of-origin rules
- Preparing price and sales documentation
- Recalculating customs duties and total landed costs
- Checking customs bond sufficiency
- Updating contracts and pricing agreements
- Coordinating shipment and entry dates
- Reviewing Incoterms and responsibility for import duties
Exporters should also discuss these requirements with their U.S. customers before confirming quotations or production schedules.
If the contract does not clearly state who is responsible for additional tariffs, the new policy could create unexpected costs or disputes between buyers and suppliers.
Five Steps Importers Should Take Now
1. Confirm the HTSUS Classification
Review the tariff classification of every polysilicon, wafer, solar cell and solar module product intended for the U.S. market.
The product description alone is not enough to determine whether the new measure applies.
2. Recalculate the Landed Cost
Include the minimum import price adjustment, the new Section 232 tariff and any existing Section 301, antidumping or countervailing duties.
Freight, insurance, customs fees, port charges and inland delivery costs should also be included.
3. Review Purchase Contracts and Incoterms
Confirm whether the buyer or seller is responsible for new import duties.
Companies using DDP, DAP, CIF, FOB or other Incoterms should ensure that the responsibilities of both parties are clearly defined.
4. Prepare Supporting Documents
Keep complete records of contracts, commercial invoices, payment terms, product specifications and sales transactions.
The documentation should support the declared customs value and the first arm’s-length sale price in the United States.
5. Plan Shipping Schedules Carefully
Review production time, vessel schedules, port cut-off dates and expected U.S. customs-entry dates.
Businesses should avoid making shipment decisions based only on the departure date because the policy applies according to the date the goods are entered for consumption or withdrawn from a warehouse for consumption.
Need Help Planning Your U.S. Shipment?
Huanhan Logistics provides international ocean freight, air freight, customs-clearance coordination and end-to-end logistics solutions for shipments from China to the United States.
If you are shipping solar modules, solar cells, silicon wafers, polysilicon or related equipment, please provide us with:
- Product name and specifications
- HTSUS code, if available
- Country of origin
- Cargo weight and volume
- Port of departure
- U.S. destination
- Expected shipping date
- Preferred Incoterm
Our team can help you review the logistics requirements, estimate shipping costs and develop a more suitable transportation plan.
Contact Huanhan Logistics for a customized U.S. shipping solution.
Sources:
White House Proclamation: “Adjusting Imports of Polysilicon and Its Derivatives into the United States”
White House Fact Sheet: “President Donald J. Trump Bolsters National Security and Strengthens U.S. Supply Chains by Imposing Tariffs on Polysilicon and Its Derivatives”
Reuters: “Trump Unveils Trade Actions to Compete with China on Solar and Chips”
Disclaimer: This article is provided for general informational purposes only and does not constitute legal, tax or customs advice. Product coverage, tariff classification and customs treatment should be confirmed with a licensed U.S. customs broker or qualified trade professional before shipment.
