Solar Products Excluded from Import Safeguard

Wednesday, September 19, 2018
Sandler, Travis & Rosenberg Trade Report

The Office of the U.S. Trade Representative has determined to exclude certain products from the safeguard on crystalline silicon photovoltaic cells and other CSPV products containing these cells. This safeguard consists of (1) a tariff-rate quota on imports of CSPV cells not partially or fully assembled into other products, with an unchanged duty rate for the in-quota quantity and a higher duty rate for over-quota articles; and (2) a higher duty rate on imports of other CSPV products.

After reviewing 48 product exclusion requests and 213 comments responding to those requests, USTR has determined to exclude the following products from the safeguard effective with respect to goods entered or withdrawn from a warehouse for consumption on or after 12:01 am EST on Sept. 19.

– off-grid, 45 watt or less solar panels, each with length not exceeding 950 mm and width of 100 mm or more but not over 255 mm, with a surface area of 2,500 cm2 or less, with a pressure-laminated tempered glass cover at the time of entry but not a frame, electrical cables or connectors, or an internal battery

– 4 watt or less solar panels, each with a length or diameter of 70 mm or more but not over 235 mm, with a surface area not exceeding 539 cm2, and not exceeding 16 volts, provided that no such panel with these characteristics shall contain an internal battery or external computer peripheral ports at the time of entry

– solar panels with a maximum rated power of equal to or less than 60 watts having the following characteristics, provided that no such panel with those characteristics shall contain an internal battery or external computer peripheral ports at the time of entry: (A) length of not more than 482 mm and width of not more than 635 mm or (B) a total surface area not exceeding 3,061 cm2

– flexible and semi-flexible off-grid solar panels designed for use with motor vehicles and boats, where the panels range in rated wattage from 10 to 120 watts, inclusive

– frameless solar panels in a color other than black or blue with a total power output of 90 watts or less where the panels have a uniform surface without visible solar cells or busbars

– solar cells with a maximum rated power between 3.4 and 6.7 watts, inclusive, having the following characteristics: (A) a cell surface area between 154 cm2 and 260 cm2, inclusive, (B) no visible busbars or gridlines on the front of the cell, and (C) more than 100 interdigitated fingers of tin-coated solid copper adhered to the back of the cell, with the copper portion of the metal fingers having a thickness of greater than 0.01 mm

– solar panels with a maximum rated power between 320 and 500 watts, inclusive, having the following characteristics: (A) length between 1,556 mm and 2,070 mm inclusive, and width between 1,014 mm and 1,075 mm, inclusive, (B) where the solar cells comprising the panel have no visible busbars or gridlines on the front of the cells, and (C) the solar cells comprising the panel have more than 100 interdigitated fingers of tin-coated solid copper adhered to the back of the cells, with the copper portion of the metal fingers having thickness greater than 0.01 mm

– modules incorporating only CSPV cells that are products of the U.S. and not incorporating any CSPV cells that are the product of any other country

USTR is still considering other exclusion requests received as of March 16 and “will make the appropriate determination in due course.” No other exclusion requests are currently being considered, but if further developments warrant USTR will provide an opportunity to submit additional requests at a future date.

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