Section 232: a $0.38/W module price floor from Dec 4

What was proclaimed

Proclamation 11052, signed on August 6, 2026 and published in the Federal Register on August 11, adjusts imports of polysilicon and its derivatives under Section 232. It sets minimum import prices (MIPs) of $21 per kilogram for polysilicon, $100 per kilogram for ingots and wafers, $0.22 per watt for solar cells and $0.38 per watt for solar modules. The Secretary of Commerce is authorized to adjust those prices "from time to time", so the figures above are the ones proclaimed, not a permanent schedule.

Both measures apply to goods "entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on December 4, 2026."

How the price floor works

For each entry, the importer documents that the first arm's-length sale in the United States will occur at or above the MIP, or that it follows fixed terms in a contract signed before August 6, 2026. Without that documentation, the entry pays a specific tariff equal to the full MIP. If the entered value is below the MIP, it pays a specific tariff equal to the difference. On top of the MIP program, covered products carry an additional 15% ad valorem duty.

Three details matter to a module buyer:

• The duties stack. The proclamation says they apply "in addition to any other duties, taxes, fees, exactions, and charges" — including antidumping and countervailing duties.
• Some origins pay less. For products of Japan, Korea, Taiwan, Switzerland, Liechtenstein or an EU member state, the 232 tariff plus the ordinary Column 1 duty equals 15%; for the United Kingdom, the clause (4) rate is 10%.
• The penalty for bad paperwork is permanent. If CBP finds an importer's documentation materially inaccurate, that importer and its affiliates are permanently barred from importing polysilicon and its derivatives.

The proclamation also notes that these tariffs replace the Section 201 safeguard tariff on cells and modules, which expired in February 2026.

No stockpiling before the deadline

A Commerce temporary final rule from the Bureau of Industry and Security, effective September 22 through December 3, 2026, targets importers bringing in polysilicon products "in volumes substantially greater than their historic averages" ahead of December 4. Those importers can be barred from further entries until the deadline. Importers of record that registered with CBP on or after August 6 are capped per week — for modules (HTSUS 8541.43.00), at 55 modules a week. In practice, a large pre-tariff build-up of new imports is hard to arrange.

What it means if you are buying modules

• Imported modules entering from December 4 carry new costs. A module priced below $0.38 per watt at entry pays the gap as a specific tariff, plus 15%, plus any AD/CVD that applies to its origin.
• The entry date is the trigger. Modules entered for consumption before December 4 were entered under the rules in force on their entry date. For December and 2027 deliveries, ask your supplier when — not just where — the modules entered.
• Price quotes need a date. A quote for future imported supply should state whether 232 duties are included. Quotes for modules already landed in U.S. warehouses do not depend on a future entry.
• Domestic and FEOC questions don't go away. The 232 action is about import price and origin of polysilicon products; tax-credit eligibility still turns on FEOC / Non-PFE documentation and, where claimed, IRA 45X or Domestic Content.

We will update this note if Commerce adjusts the MIPs or amends the product annexes.