Preliminary CVD determinations on India, Indonesia, and Laos drive a potential shift in U.S.-bound PV exports toward the Middle East and Africa

On February 24, 2026 (U.S. Eastern Time), the U.S. Department of Commerce (DOC) issued its preliminary countervailing duty (CVD) determinations on PV cells imported from India, Indonesia, and Laos, as well as modules assembled with cells from these countries and exported to the U.S. The investigation period spans January to December 2024. With the list of manufacturers now announced, the market is closely assessing the implications for cost structures and potential supply chain realignment.

Following the U.S. federal government shutdown and multiple investigation extensions, the preliminary anti-dumping (AD) determinations are expected by April 21, 2026, with final rates for both the CVD and AD investigations scheduled for release by July 6, 2026. InfoLink analyzes the preliminary CVD determinations and evaluate their structural impact on the evolving market landscape.
 

Critical circumstances determinations: certain Indonesian and Indian manufacturers are subject to 90-day retroactive duties

Notably, the determinations apply affirmative findings of “critical circumstances” to PT Blue Sky and “All Others” producers in Indonesia, as well as Mundra-affiliated entities in India. This allows the DOC to impose CVD retroactively on import surges that occurred prior to the preliminary determinations, protecting the U.S. domestic industry from last-minute shipment rushes..

In these investigations, the 90-day retroactive period under critical circumstances is calculated from the expected publication date of February 26, 2026 (U.S. Eastern Time). Thus, subject products entered on or after November 28, 2025, will be subject to retroactive CVD duties. For producers not subject to the critical circumstances finding—including PT REC in Indonesia, “All Others” producers in India, and all investigated manufacturers in Laos—duties will apply from the date of publication of the preliminary determination.
 

Escalating policy risks may redirect primary U.S.-bound cell supply toward the Middle East and Africa

With large-scale U.S. domestic cell capacity unlikely to come online in the near term, the imposition of high duty rates on India (125.87%), Indonesia (85.99%–143.30%), and Laos (80.67%) has significantly undermined the economic viability of traditional sourcing routes. Apart from Malaysia, which faces relatively lower duties, and the Philippines, where capacity is gradually ramping up, most Southeast Asian production bases have largely lost their export competitiveness in the U.S. market.

Given current duty differentials, as cell expansion projects in Ethiopia, Nigeria, and Türkiye come online, the center of U.S. cell imports is expected to shift materially. Middle East and Africa-origin supplyis likely to replace Southeast Asia as the primary sourcing region for U.S. module demand.

As early as 2Q26, incremental capacity ramp-up in the Middle East and Africa, together with the phased commissioning of U.S. domestic cell lines, is expected to gradually close the overall supply gap.
 

Navigating policy volatility: compliance and localization emerge as core competitive advantages

In addition to elevated tariff pressure, the rollout of detailed foreign entity restrictions under the One Big Beautiful Bill Act (OBBBA) has further intensified policy uncertainty in the U.S. PV market. For manufacturers seeking sustained participation in the U.S. market, proactive policy monitoring and strict compliance checks on upstream material sourcing are now imperative to meet increasingly stringent market access requirements.

Over the longer term, competition in the U.S. PV market has shifted from cost advantage to a broader emphasis on supply chain compliance and localized manufacturing. As the industry moves into a policy-driven restructuring phase, manufacturers’ ability to anticipate regulatory changes, manage tariff risks, and align with stringent U.S. compliance standards will be critical to securing future market opportunities.