Preventing the stockpiling of polysilicon imported to the US is a “critical” step to ensuring that Section 232 tariffs and minimum import prices will be effective.
This is the opinion of Matt Card, president and COO of US cell manufacturer Suniva, one of several industry experts to speak to PV Tech Premium about rules to limit polysilicon imports. The new rules were announced last week, and function as a bridge to 4 December, when the Section 232 tariffs and minimum import prices on polysilicon, which were first announced in August, will come into force; in effect, the new rules are intended to prevent US manufacturers from purchasing large quantities of polysilicon from overseas before the tariffs and minimum prices take effect.
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“Protecting against stockpiling is critical to ensure a functionally viable remedy from the Section 232 rules,” Card told PV Tech Premium exclusively, adding that the new rules will have to address importers of all shapes and sizes to ensure large-scale stockpiling does not take place.
“Because the rule attempts to prevent stockpiling, that means it has to address both established importers and new importers,” he explained. “If it only addressed one of those two, the unaddressed entities could be used to rapidly import and build stockpiles.”
However, Aaron Hall, president of Anza, expressed some concern that the threat of stockpiling risk could create some “inflationary prices” in the US solar sector. He spoke to PV Tech last week about his company’s latest pricing data, which shows US module import prices have risen more than 40% since the announcement of the Section 232 tariffs, and further barriers to US module imports could push prices further upwards.
“Current price increases definitely are a result of Section 232,” he said. “Modules must now incorporate an MIP and AV tax on whatever component is being imported.
“There is also some rush to beat the buzzer, despite very real stockpiling risk, and this is creating some inflationary prices as there is a spike in demand for raw materials and cells that are outside of anti-dumping and countervailing duty (AD/CVD)-impacted countries.”
Card added that, despite these price pressures, the current US policy landscape is one that incentivises more investment in manufacturing; he told PV Tech Premium earlier this month that the One Big, Beautiful Bill Act (OBBBA) set the tone for a greater emphasis on manufacturing, and that Section 232 is “good for US manufacturing growth”.
“I do think this shows the administration’s seriousness that is going to rapidly address prospective deficiencies and loopholes,” he told PV Tech Premium this week. “The original proclamation said the administration would take steps to prevent stockpiling and that is exactly what these new rules are intended to do.”
‘This action does not change anything for manufacturers’
Card was similarly optimistic that the new anti-stockpiling rules wouldn’t disrupt manufacturing efforts in the US, as manufacturers ought to be looking for domestic sources of polysilicon already. Despite figures from PV Tech Research showing a “persistent shortfall” in domestic US polysilicon manufacturing, with just 15.5GW of PV-allocated production capacity, Card argued that Suniva’s work as a domestic cell manufacturer demonstrates the feasibility of onshoring the manufacturing supply chain.
“This action does not change anything for any manufacturer that is committed to truly building US manufacturing,” he explained. “It’s a strong signal that circumvention is going to be both uncovered and stopped. “Suniva believes that as the most mature cell manufacturer in the US, we have developed a wafer procurement strategy that supports the policies the US government is establishing.”
Martin Pochtaruk, CEO of module manufacturer Heliene, was similarly optimistic. His company signed a supply agreement with polysilicon and wafer manufacturer Corning, and Suniva, last year, to build a wholly US-based supply chain from polysilicon to wafers to cells and modules, and told PV Tech Premium this week that the new stockpiling rules wouldn’t change that dynamic.
“Heliene is already supplying the US market with US polysilicon, wafers, cells and modules, exactly doing what the 232 safeguard measure wants to push for,” he explained. “Imports for sure will need to abide by the minimum import price and the market will determine if the future annual volume is lower, same or higher in terms of market demand and supply.”
He also echoed Hall’s sentiments that these rules could put upward pressure on prices—saying that “the power generation market might result having a higher capex”—but added that measures such as these were important to create level playing fields for US manufacturers.
Anti-stockpiling rules within a broader policy landscape
The latest rules also fit into a broader policy landscape that aims to reduce the US’ reliance on overseas imports. Chief among these has been the ongoing AD/CVD investigations—this month the Department of Commerce (DOC) finalised duties on India, Indonesia and Laos—and PV Tech Research analyst Joe Hennessy told us last week that the combination of more widespread AD/CVD rules and the new polysilicon stockpiling limits fit neatly together.
“Generally, as AD/CVD investigations were ongoing, developers would purchase a lot of modules and module manufacturers would purchase cells before the deadline hit to continue to manufacture or deploy using the products from the countries about to be tariffed heavily,” said Hennessy. “These measures will aim to stop this practice.”
Last week’s rules also constitute a more robust effort to reduce reliance on overseas imports than policies introduced by the Biden administration. In 2022, Biden temporarily suspended new duties on imports of cells and modules from Cambodia, Malaysia, Thailan and Vietnam, and Card expressed concern at “the lengths people took to build up stockpiles of modules” before the return of these duties in 2024.
“The aim of that measure is to prevent what happened in December 2024 when the Biden-era import moratory came to an end and we found almost two years’ worth of imports brought in overnight—hence stockpiling to circumvent the measure itself,” added Pochtaruk, pointing to the stockpiling of products that accompanied the Biden-era efforts to reduce reliance on imports.
Analysis from the Coalition for a Prosperous America, using figures from Wood Mackenzie and the Solar Energy Manufacturers for America (SEMA) Coalition, found that around 42.5GW of solar panels and 7.5GW of cells were imported and not deployed in this period, which translates to around US$12.53 billion worth of stockpiled inventory in this period.
“This is not the first time, as you mention, for the DOC to do what is proposed; the US pharmaceutical industry just went through exactly the same process on their own 232 safeguard,” continued Pochtaruk, who argued that policies like these are often not targeted at a single sector, but towards the broader goal of US supply chain independence across industries.
“The US DOC does not respond to the global situation of any commodity … but only to what they deem appropriate for the US economy.”
The impacts of the policy landscape on the US solar sector will be a key topic of conversation at our annual PV CellTech conference on 13-14 October in San Francisco. For the full agenda and information on tickets, click here.
