U.S. imposes Section 232 measures on polysilicon and derivatives: Key provisions and industry impacts

Overview

On August 6, 2026, U.S. President Donald Trump signed a proclamation under Section 232 of the Trade Expansion Act of 1962, introducing measures targeting imports of polysilicon and its derivative products. The proclamation followed a report submitted to the President by the U.S. Secretary of Commerce following an investigation under  Section 232. The report concluded that these products were being imported into the U.S. in such quantities and under such circumstances as to threaten to impair U.S. national security. After reviewing the report, President Trump concurred with the Secretary’s findings and issued the proclamation accordingly.

Unlike the original petition, the proclamation does not adopt a two-tier tariff structure in the form of a tariff-rate quota (TRQ). Instead, it establishes a minimum import price (MIP), imposes an ad valorem duty (AVD) on derivative products, and introduces an onshoring program to revitalize the U.S. polysilicon industry and ensure that imports do not threaten national security.
 

Key measures and PV products covered

1. MIPs for polysilicon and derivative products

(i) Polysilicon: USD 21/kg

(ii) Ingots and wafers: USD 100/kg

(iii) Solar cells: USD 0.22/W

(iv) Solar modules: USD 0.38/W

*NOTE: The Secretary of Commerce may adjust these MIPs from time to time to reflect market conditions or other factors affecting the fair market value of the covered products under undistorted, free market conditions.

2. AVD on imported polysilicon and derivative products

(i) Polysilicon: None

(ii) Ingots and wafers: 15%

(iii) Solar cells: 15%

(iv) Solar modules: 15%

3. Onshoring program for imported polysilicon and derivative products

Under Sections 6 (a) and 6 (c) of the proclamation, the Secretary of Commerce is authorized to establish an incentive program to encourage investment in U.S. production of polysilicon, ingots, wafers, and cells. Companies seeking to participate must submit an onshoring plan committing, following approval of the plan, to build, renovate, or expand U.S. facilities that manufacture covered products. Construction must begin by January 20, 2029. Once an onshoring plan is approved, the Secretary of Commerce may grant the participating company conditional relief from Section 232 tariffs for imports of necessary production equipment and covered products, subject to the terms and limits of the program.

InfoLink’s key takeaways on the tariff structure: 

1.    Total duties payable = (MIP – import price) + import price x (Column 1 General rate of duty + 15%). If the import price exceeds the MIP, only the following duties apply: import price x (Column 1 General rate of duty + 15%).

2.    If the required supporting documentation is not provided, total duties payable will instead be calculated as follows: MIP + import price x (Column 1 General rate of duty + 15%).

*Note 1: The Column 1 General rate of duty refers to the standard tariff rate applied to imports from countries eligible for most-favored-nation (MFN) treatment, known in the U.S. as normal trade relations status. The rate is 0% for solar-grade polysilicon, wafers, cells, and modules.

*Note 2: For products from Japan, South Korea, Taiwan, Switzerland, Liechtenstein, or EU member states subject to the tariffs under this proclamation, the combined Column 1 General rate and additional tariff will be 15%. For products from the U.K., the applicable rate will be 10%.
 

Implementation timeline for the Section 232 measures

Points to note: 

1. To address potential stockpiling, Section 11 of the proclamation provides that if the Secretary of Commerce determines that a company engaged in stockpiling before the measures take effect on December 4, the Secretary shall coordinate with U.S. Customs and Border Protection (CBP) to restrict imports by the company and its affiliated entities. 

2. For foreign trade zones, Section 7 provides that covered products admitted into the U.S. foreign trade zones after December 4 must be admitted under “privileged foreign status.” This provision is intended to prevent importers from using foreign trade zones to defer customs entry and avoid the applicable tariffs. 
    

InfoLink insights

1. The implementation of the Section 232 measures is expected to significantly improve the price competitiveness of U.S.-made products relative to imports. Before the Section 232 measures, imported modules were priced at USD 0.25-0.27/W FOB, compared to USD 0.30-0.33/W for modules assembled in the U.S. The gap was wider for cells, with imported cells priced at USD 0.12-0.16/W, compared with USD 0.20-0.25/W for U.S.-made cells. By raising the cost of imported products, the Section 232 measures are expected to narrow the price gap between imported and domestically manufactured products. 

2. For exporters, raising selling prices to the MIP level could significantly improve margins while reducing the Section 232 tariff burden. However, the feasibility of doing so will ultimately depend on product scarcity and buyers’ willingness to accept higher prices. For example, if imported module prices rise to the MIP of USD 0.38/W, demand for imported modules would likely be limited given ample domestic module supply in the U.S. and the lack of a meaningful price advantage. InfoLink expects that imported modules will no longer hold a price advantage once the Section 232 measures take effect. Some demand for imported polysilicon, wafers, and cells, however, is likely to remain in the near term due to supply shortages in the U.S. market. 

3. For domestic manufacturers, the Section 232 measures will also raise production costs in the U.S., pushing up prices for U.S.-made modules. This will be particularly evident for manufacturers that rely on imported cells, wafers, or polysilicon, as higher costs are likely to be passed through to module prices. Based on current estimates, U.S.-assembled module prices could rise from around USD 0.30–0.33/W to more than USD 0.40/W for manufacturers to maintain reasonable gross margins.

4. For U.S. developers, the MIP mechanism will raise the cost of upstream materials, pushing up module prices for both imported and domestically manufactured products, and in turn, affecting project costs and returns. However, as modules are no longer the largest cost component for U.S. solar projects, they are expected to have only a limited impact on investment appetite for solar projects.

5. Over the longer term, Section 232 is expected to raise barriers to imports and create a more favorable environment for the development of a domestic solar manufacturing ecosystem, supporting the U.S. manufacturing capacity expansion. However, whether the policy can ultimately bring manufacturing capacity back to the U.S. will depend on more than tariffs and domestic manufacturing requirements. While these measures can provide protection and support for U.S. manufacturers, the effectiveness of the onshoring program in attracting investment and providing sufficient incentives will be critical. 

6. Before the Section 232 proclamation was issued, the U.S. already had around 55,000 MT (around 29 GW) of polysilicon capacity, 5.3 GW of wafer capacity, 9.3 GW of cell capacity, and 92.8 GW of module capacity, including First Solar. These figures do not include projects planned by Tesla and SpaceX. With further capacity expected to come online over the next several years, the U.S. is poised to develop a sizable domestic solar manufacturing ecosystem.

This article presents InfoLink Consulting’s analysis based on the text of the proclamation and is provided for industry reference. The final interpretation and determination of the relevant policies, as well as their implementation, remain subject to official guidance from the relevant U.S. authorities. For calculations under the tariff structure, the impact on costs and profitability across supply-chain segments, and analysis of the implications for exporters and importers, please refer to InfoLink’s member-exclusive report, U.S. Section 232 Measures on Polysilicon and Its Derivative Products: An Impact Analysis