Solar IV orders signed: deposits run from Nov 5

What Commerce filed

The CVD orders (FR Doc. 2026-22824, 91 FR 70843) and the AD orders (FR Doc. 2026-22825, 91 FR 70862) are both dated November 4, 2026. They follow the ITC's final injury determinations, which the Commission sent to Commerce on November 2 and which were published in the Federal Register on November 5 at 91 FR 69865. For background on that vote, see our note on the ITC filing.

Both notices say that, effective on the date the ITC's final determination was published in the Federal Register, CBP "will require, at the same time as importers would normally deposit estimated customs duties" on subject merchandise, a cash deposit equal to the listed rates.

The rates, with one correction

The CVD rates are the final ones published in September. The AD notice also amends the Laos final determination to correct a ministerial error, which moves the Laos rate up slightly: a 65.76% dumping margin and a 65.36% cash deposit after subsidy offset, up from 65.43% and 65.03%. The all-others cash deposit rates (for Laos AD, the Laos-wide entity rate) are now:

• India: 107.17% AD + 126.09% CVD = 233.26% of entered value.
• Indonesia: 94.36% AD + 73.20% CVD = 167.56%.
• Laos: 65.36% AD + 82.03% CVD = 147.39%.

The sums are our arithmetic on Commerce's published rates. Several companies carry higher rates based on adverse facts available; the September final determinations list them.

The gaps and the look-backs

Provisional measures have legal time limits, and the orders spell out what happens to entries made while they had lapsed:

• AD gap: the AD provisional period ended October 24, 2026. Entries from October 25 through the day before the ITC notice was published are to be liquidated "without regard to antidumping duties."
• CVD gap: the CVD provisional period ended June 25, 2026. Entries from June 26 through the day before the ITC notice was published are not subject to countervailing duties.
• Critical circumstances: for India and Laos, where the ITC's finding was negative, Commerce intends to refund CVD cash deposits on entries made from November 28, 2025 through February 25, 2026. For Indonesia, where both agencies found critical circumstances, retroactive CVD applies to entries from November 28, 2025.

What is in scope

The orders cover cells "whether or not partially or fully assembled into other products," classified under HTSUS 8541.42.0010 and 8541.43.0010, with other listed subheadings for products such as generators. Origin follows the cell: "Modules, laminates, and panels produced in a third-country from cells produced in a subject country are covered by the orders," while modules assembled in a subject country from third-country cells are not. Products already covered by the China orders are excluded.

What it means if you are buying modules

• The orders are now the baseline. Any new entry of covered cells or modules from these three countries carries AD and CVD cash deposits from November 5, on top of normal customs duties.
• Ask for cell origin in writing. A module's assembly country does not decide the question; the cell's country does.
• Check the timing on recent entries. If you imported before November 5, the gap and critical-circumstances rules above decide what was owed. Confirm who carries any later review liability.
• More is coming on December 4. Imported modules then also face the Section 232 price floor and 15% duty. Modules already landed in a U.S. warehouse were entered under the rules in force at the time.

The links above now point to the published Federal Register text; the final duty on these entries is set later, as explained in our note on reviews.