Solar III: first duty reviews for SE Asia modules

What Commerce started

In a notice published on August 10, 2026 (FR Doc. 2026-16265, 91 FR 51436), Commerce initiated administrative reviews of orders "with June anniversary dates." The list includes all eight "Solar III" orders: an antidumping (AD) and a countervailing duty (CVD) order for each of the four countries. Each review names a long list of producers and exporters.

The orders date from June 24, 2025. They are set out in the AD orders notice (90 FR 26786) and the CVD orders notice (90 FR 26791).

The periods under review

The initiation notice sets these periods of review:

• AD, Malaysia and Vietnam: December 4, 2024 to May 31, 2026.
• AD, Cambodia and Thailand: June 13, 2025 to May 31, 2026.
• CVD, Malaysia and Vietnam: October 4, 2024 to December 31, 2025.
• CVD, Cambodia and Thailand: June 13, 2025 to December 31, 2025.

The later start for Cambodia and Thailand follows from the orders themselves. There, the ITC found a threat of material injury rather than present injury, so duties are assessed only from the publication of the ITC's final determination. The orders also leave out entries made between the end of the provisional measures period and that publication. For the AD orders, that gap starts on June 2, 2025, "the first day provisional measures were no longer in effect."

The deposit rates now being tested

The cash deposit rates in the 2025 orders vary widely by country. For companies without their own rate, the orders set:

• AD (cash deposit, adjusted for subsidy offsets): Cambodia 117.18%, Malaysia 1.92%, Thailand 111.45%, and 271.28% for the Vietnam-wide entity.
• CVD (all others): Cambodia 534.67%, Malaysia 34.09%, Thailand 255.39% and Vietnam 124.57%.

AD and CVD are separate orders, so a module can carry both. These are deposits, not final duties. Under 19 CFR 351.212, the review result replaces the deposit for the entries in the period. If the reviewed rate is higher, the importer of record pays the difference. If it is lower, the difference is refunded. Our Solar IV deposits note explains the same mechanism for the newer orders on India, Indonesia and Laos.

The timeline

Under the initiation notice, parties could withdraw their review requests within 90 days of publication. Our count puts that at November 8, 2026. Under 19 CFR 351.213(h), Commerce issues preliminary results "within 245 days after the last day of the anniversary month." For a June anniversary, our count gives March 2, 2027. Commerce may extend that to 365 days, which our count puts at June 30, 2027. Final results follow 120 days after the preliminary results are published, extendable to 180 days. When we searched the Federal Register on November 14, 2026, we found no preliminary results or rescissions for these reviews.

What it means if you are buying modules

• Duties on older entries are still open. Modules entered from these four countries during the review periods can still be assessed at a different rate. That liability sits with the importer of record, not with a later buyer. If you imported directly, check who carries it under your contract.
• Cell origin decides coverage. The scope covers crystalline silicon cells "whether or not partially or fully assembled into other products," including modules. Thin film is excluded. A module assembled elsewhere with cells from one of these countries can be in scope.
• New entries still pay deposits. Until a review finishes, each new entry pays the deposit rate on file for its producer and exporter.
• Know which order you are looking at. Solar III (Southeast Asia) and Solar IV (India, Indonesia and Laos) are separate orders with different review calendars.