China solar AD: 2020 entries get lower margins

What Commerce filed

On November 12, 2026, Commerce placed a notice of amended final results on public inspection. It is scheduled for publication in the Federal Register on November 13, 2026 and is "applicable November 8, 2026". It concerns the antidumping (AD) order on crystalline silicon photovoltaic cells, whether or not assembled into modules, from China (case A-570-979), and the 2019-2020 administrative review, which covers the period "December 1, 2019, through November 30, 2020."

On October 29, 2026, the U.S. Court of International Trade issued its final judgment in Consol. Court No. 22-00219, sustaining Commerce's third remand results. Commerce says that judgment "is not in harmony" with its final results of the review, so it is amending them.

The numbers

The amended final results Commerce published in August 2022 set margins of 20.99 percent and 12.24 percent for the two exporter groups it examined, and a separate rate of 14.79 percent for non-examined companies that qualified. After three remands, which turned partly on the surrogate value used for solar glass, the amended margins are:

• First examined exporter group: 4.76 percent, down from 20.99 (a cut of 16.23 points, our arithmetic).
• Second examined exporter group: 0.00 percent, down from 12.24.
• Three non-examined companies that litigated: 4.76 percent, down from the 14.79 percent separate rate.

A sixth exporter group that appealed was found not eligible for a separate rate. Commerce says its margin "is not affected" by these amended results.

Cash deposits today: mostly unchanged

The notice separates old entries from current deposits. Four of the companies already have a "superseding cash deposit rate" from later reviews, so Commerce "will not issue revised cash deposit instructions" for them and the notice "will not affect the current cash deposit rates for these companies." The group now at 0.00 percent has no later rate, so Commerce will send CBP a revised cash deposit instruction for it.

When the 2020 entries settle

Liquidation is still on hold. Commerce "remains enjoined" by the court from liquidating the covered entries, and they "will remain enjoined" while any appeal runs. If the ruling is not appealed, or is upheld by a "final and conclusive" decision, Commerce will tell CBP to assess AD duty under 19 CFR 351.212(b). That rule divides the dumping margin by the entered value to get an assessment rate for each importer.

Where that rate is "zero or de minimis," CBP will liquidate "without regard to antidumping duties." Under 19 CFR 351.106(c)(2), de minimis in an assessment means "less than 0.5 percent ad valorem." Section 351.212(a) explains why this happens at all: the U.S. uses a "retrospective" system in which "final liability" for AD and CVD duties "is determined after merchandise is imported."

What it means if you are buying modules

• AD duty can stay open for years. These entries were made in 2019 and 2020. The review results came in 2022, and the duty is still not final in November 2026. Final duty can come out lower than the deposit, as it does here, or higher.
• The importer of record holds the result. Refunds or bills land with whoever entered the goods. If you import, your contract should say who keeps a refund and who pays an increase.
• Today's deposits come from later reviews. For most of the companies covered, the rate on new entries comes from more recent reviews, not from this one.
• The same mechanics apply to the new orders. Deposits on cells and modules from India, Indonesia and Laos work the same way; our Solar IV cash-deposit note walks through their review timeline.

Next date to watch

The Federal Register publication on November 13, 2026, and whether any party appeals the October 29 judgment. Until that question is settled, the 2019-2020 entries stay unliquidated.