US solar developers have less than a month before new Section 232 trade measures on polysilicon, wafers, cells and modules take effect on 4 December, and many still do not know how imported panels will be priced, pv magazine USA reported on 6 November.
The measures, set by a proclamation signed on 6 August, combine new tariffs with minimum import prices of US$0.22 per watt for solar cells and US$0.38 per watt for modules.
"Without further guidance from the government, it is hard for the market to price solar modules today," said Sabah Bayatli, chief executive of San Antonio-based developer OCI Energy.
How the price floors work
According to a summary by law firm Hunton, the floors are also set at US$21/kg for polysilicon and US$100/kg for silicon ingots and wafers. Covered polysilicon derivatives generally face an additional 15% Section 232 tariff, while products from the United Kingdom face 10%.
The minimum price is tested against the first arm's-length sale of the goods in the US. If importers do not document that this sale meets the floor, a specific tariff equal to the minimum price applies. If the entered value is below the floor, the tariff equals the gap. Sales under fixed-term contracts signed before the proclamation can qualify for an exception.
The measures replace the Section 201 solar safeguard tariffs, which expired on 7 February 2026.
Developers are still waiting for procedures
pv magazine USA reports that US Customs and Border Protection and the Department of Commerce are expected to issue instructions on the self-certification forms importers will need to clear shipments after the deadline.
Bayatli said it "comes down to whether a manufacturer who imports cells from outside the country is able to sell" in the US market after the deadline.
The industry has already been through several deadlines this year, including the 4 July construction-start cutoff, the 24 July tariff transition, foreign entity of concern restrictions and Federal Communications Commission rules on inverter components. Solar equipment inventories in the US rose 126% in the second quarter as developers sped up purchases, the publication reports.
Who carries the cost
Projects that are funded and under construction are largely protected, because their hardware was contracted earlier. The main exposure is in long-term purchasing for projects planned for 2027 and beyond.
OCI Energy uses contracts that share policy risk among sponsors, equipment suppliers, construction contractors, lenders and buyers. "In the contract, you see change in law or change in tariff clauses that allow the developer to share risk," Bayatli said.
When costs cannot be absorbed, they move to electricity buyers. "Eventually, any additional tariffs that you did not bake inside your financial model will flow into the power pricing," Bayatli said. "What that translates to is having a higher PPA pricing to make the project economically work."
What it means for the US solar market
The 4 December floors set a clear minimum for imported cells and modules, but without customs procedures, buyers cannot yet price deliveries for 2027. Developers that build change-in-law clauses into contracts are better placed, and corporate buyers should expect some of the cost to appear in power purchase agreement prices.
"Developers will always find a way," Bayatli said, but for now the burden is on contracts rather than on spot purchases.
Source: pv magazine USA and Hunton, 6 November 2026.
