Trade Advisory: United States Imposes New Section 232 Measures on Polysilicon and Solar Supply Chain Products

August 2026

Overview

The President has issued a proclamation under Section 232 of the Trade Expansion Act of 1962 determining that imports of polysilicon and certain polysilicon derivative products threaten to impair the national security of the United States. As a result, the Administration will implement a combination of Minimum Import Prices (MIP), additional tariffs, and domestic manufacturing incentives designed to strengthen the U.S. polysilicon and solar manufacturing supply chain.

The new requirements will apply to covered products entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on December 4, 2026.

Key Trade Measures

Minimum Import Price (MIP) Program

The proclamation establishes the following minimum import prices for covered products:

Product	Minimum Import Price
Polysilicon	$21 per kilogram
Polysilicon Ingots and Wafers	$100 per kilogram
Solar Cells	$0.22 per watt
Solar Modules	$0.38 per watt

 

The Secretary of Commerce may adjust these MIP levels periodically to reflect market conditions and fair-market pricing.

Import Documentation Requirements

Importers must provide documentation to U.S. Customs and Border Protection (CBP) demonstrating that:

• The first arm's-length sale in the United States will occur at or above the applicable MIP; or
• The sale is governed by a contract entered into before the date of the proclamation.

If sufficient documentation is not provided the imported merchandise will be assessed a specific tariff equal to the applicable MIP.

If documentation is provided but the entered value is below the MIP the importer will be required to pay a specific tariff equal to the difference between the declared value and the applicable MIP.

CBP is directed to monitor compliance with MIP certification requirements. Importers found to have submitted materially inaccurate information or failed to comply with certification obligations may face permanent prohibition from importing covered products into the United States, penalties and other enforcement actions authorized under U.S. law.

Additional Section 232 Duty

In addition to the MIP program, covered imports of polysilicon derivatives identified in the proclamation will be subject to an additional 15% ad valorem Section 232 duty.

Special Country Provisions

For imports originating from European Union member states, Japan, South Korea, Taiwan, Switzerland, and Liechtenstein the combined Column 1 duty rate and Section 232 tariff will equal 15%.

For imports originating from the United Kingdom the applicable Section 232 tariff rate will be 10%.

Products classified under the HTSUS provisions will be subject to the new Section 232 tariffs and Minimum Import Price (MIP) program.

Domestic Manufacturing Incentive Program

The Department of Commerce has been authorized to establish an onshoring program to encourage investment in U.S. manufacturing facilities producing raw polysilicon, ingots, wafers, and solar cells. Companies submitting approved domestic investment plans may receive temporary relief from Section 232 duties on qualified production equipment and covered products needed to support facility construction and expansion. Failure to meet approved commitments may result in the loss or retroactive recovery of duty benefits.

Drawback Provisions

Manufacturing drawback under 19 U.S.C. §1313(a) and (b) will be permitted for duties imposed under this proclamation when specified criteria are met.

Eligibility generally requires merchandise not subject to antidumping or countervailing duty orders, products originating from designated trade agreement partners, and polysilicon content sourced entirely from qualifying partner countries.

Importer Considerations

Importers of polysilicon, wafers, solar cells, solar modules, and related products should review product classifications and determine whether imported merchandise is covered by the proclamation, assess pricing structures against the new minimum import price requirements, prepare documentation and certification procedures necessary to support MIP compliance, evaluate the impact of the additional 15% Section 232 tariff, consider supply chain and sourcing alternatives that may qualify for preferential treatment under the proclamation.

Disclaimer

This advisory is provided for informational purposes only and does not constitute legal advice. The information is based on publicly available government sources, including the President’s Proclamation “Adjusting imports of polysilicon and its derivatives into the United States”, available as of August 6, 2026. Trade regulations, filing requirements, duty payment procedures, and administrative processes may be modified, clarified, or supplemented through subsequent Federal Register notices, CBP guidance, or other government actions. Importers should consult qualified legal counsel and trade compliance professionals before making decisions based on evolving customs compliance requirements.

How Crane Trade Consulting Can Help

Crane Trade Consulting can help importers assess product coverage, review HTS classifications and valuation, evaluate Section 232 duty and MIP exposure, prepare supporting documentation, and identify potential duty recovery or drawback opportunities. Our Trade Advisors can also assist with post-entry reviews, compliance readiness, and monitoring future CBP guidance or regulatory updates as well as additional consulation on a case-by-case basis, please  Crane Trade advisors.