Daily Trade News · Customs, Duties & Sanctions
Solar Duty Decisions Land
Final solar-cell determinations reach India, Indonesia and Laos, new trade-remedy orders take effect, and customs and sanctions rules shift.
September 19, 2026Commerce finalized six antidumping and countervailing-duty investigations covering crystalline silicon photovoltaic cells and modules from India, Indonesia and Laos. The determinations establish high final rates and country-specific critical-circumstances treatment, but permanent orders still depend on the USITC's final injury decisions.
Solar-cell investigations move to the injury stage
The final determinations cover crystalline silicon photovoltaic cells, whether or not assembled into modules. Product scope—not an HTSUS number alone—controls. Modules made in a third country from cells produced in a subject country remain covered, while modules made in a subject country from third-country cells are outside these investigations.
| Origin | Final AD result | Final CVD result | Collection and timing note |
|---|---|---|---|
| India | 123.04% margin Final adjusted deposit table: 107.17% | 126.09% Mundra Solar Energy, Mundra Solar PV and all others | The CVD provisional period ended June 26. Commerce says the AD deposit is not adjusted to 107.17% while CVD deposits are not being collected. If both injury findings are affirmative, the adjusted AD rate applies at the order stage. |
| Indonesia | 94.36% Blue Sky, REC Solar and all others | 73.20% / 173.70% REC Solar and all others: 73.20%; Blue Sky: 173.70% | Final critical circumstances were affirmative for all AD respondents and all others. The CVD provisional period ended June 26; permanent CVD collection awaits an order. |
| Laos | 65.43% margin Final adjusted deposit table: 65.03% | 82.03% / 153.67% Solarspace and all others: 82.03%; VSUN: 153.67% | AD critical circumstances apply to certain named exporters and the Laos-wide entity. CVD critical circumstances apply to VSUN and all others, but not Solarspace; the CVD provisional period ended June 26. |
Critical-circumstances treatment is not uniform. Among other differences, India's CVD determination reaches qualifying Mundra entries back to November 28, 2025, while India's AD determination uses January 28, 2026 for several named companies. Indonesia's AD determination reaches back 90 days from the April 28 preliminary determination. Entry-by-entry review is therefore essential.
Primary sources: Commerce's final solar determinations for India AD and India CVD; Indonesia AD and Indonesia CVD; and Laos AD and Laos CVD.
New orders activate deposits on lysine, rebar and wire rod
| Product and origin | AD cash-deposit treatment | CVD cash-deposit treatment | Important limit |
|---|---|---|---|
| L-lysine — China | Named combinations: 73.37% or 139.65%; China-wide entity: 139.65% | Inner Mongolia Eppen and all others: 48.21%; two AFA entities: 82.11% | Rates are producer/exporter or company specific. The AD and CVD percentages are not a single universal combined rate. |
| Rebar — Bulgaria | Promet Steel and all others: 53.27% | Not applicable in this order | Apply only to merchandise within the written rebar scope. |
| Rebar — Egypt | Ezz and all others: 34.20%; Marakby and Suez Steel: 52.73% | Ezz and all others: 23.27% | Company identity determines both AD and CVD treatment. |
| Rebar — Vietnam | Hoa Phat adjusted deposit: 123.49%; Vietnam-wide: 131.53% | Hoa Phat and all others: 6.80% | The Vietnam-wide AD rate does not replace Hoa Phat's separate-rate treatment. |
| Steel wire rod — Algeria | Not applicable in this order | Algerian Qatari Steel and all others: 73.33% | The CVD order takes effect without a USITC injury determination because Algeria is treated as a non-Subsidies Agreement country for this proceeding. |
A separate final administrative review set SeAH Steel VINA's Vietnam oil-country tubular goods AD cash-deposit rate at 15.52%; the Vietnam-wide rate remains 111.47%. That review result is company-specific and is not a new country-wide rate.
Primary sources: China L-lysine orders; rebar AD orders; rebar CVD orders; Algeria wire rod CVD order; and Vietnam OCTG final review.
CBP corrects Section 338 validation and sets ACE dates
CBP corrected ACE error F884, “EXEMPT HTS NOT ALLOWED FOR SECTION 338.” The September 17 correction replaces the erroneous reference to 9903.03.05 with 9903.03.15. ACE rejects 9903.03.15 unless the line also reports an appropriate dutiable Section 338 Chapter 99 number. The validation had already been deployed to certification and production on August 26; the change corrects the published description rather than announcing a fresh tariff.
CBP also published Entry Summary Create/Update changes with two operational dates. Version 111 Entry Type 13 changes are scheduled for production on September 22, 2026. Version 110 implements fiscal-year 2027 COBRA user fees for importations on or after October 1, 2026, including entry summaries pre-filed before that date when the entry date is October 1 or later.
Primary sources: CBP CSMS #69941677, Section 338 validation correction, and #69915041, Entry Summary Create/Update changes.
Canada procurement review begins; HTS archive confirms Revision 19 sources
A September 16 presidential memorandum directs OMB and USTR, in coordination with the Federal Acquisition Regulatory Council, to identify and take all legally permitted steps to remove or make unavailable Canadian-origin items in federal civil procurement and to alert agencies to domestic alternatives. It does not itself publish a product list, customs prohibition or across-the-board effective date, so suppliers should watch for acquisition-system implementation rather than treating the memorandum as an import ban.
The USITC HTS Archive still lists 2026 Revision 19, dated September 15, as the current edition. The archive now expressly identifies two Modification Sources: the Canada alcoholic-beverage and motor-vehicle Section 338 scope proclamations. Those measures took effect for covered entries at 12:01 a.m. EDT on September 15 and alter the products assigned to 9903.03.12 and 9903.03.14. This corrects the earlier conclusion that Revision 19 had no listed modification source.
Primary sources: White House procurement memorandum; USITC HTS Archive; Canada alcoholic-beverage scope proclamation; and Canada motor-vehicle scope proclamation.
Sanctions and export-control rules change on Ethiopia, Russia and Venezuela
- Ethiopia: The national emergency under Executive Order 14046 expired on September 17. OFAC removed all persons designated under that authority and retired the related program FAQs. A parallel State Department final rule, effective September 18, removes Ethiopia's ITAR policy of denial and also clarifies Canada exemption paperwork, Somalia licensing policy, and major non-NATO ally entries.
- Lukoil assets: Russia General License 131J authorizes negotiations and contingent contracts for the sale of Lukoil International GmbH and permits specified maintenance and wind-down activity through October 22, 2026. It does not authorize consummating a sale; that still requires separate OFAC authorization.
- Venezuela bonds: General License 5Z moves the authorization date for specified transactions involving the PdVSA 2020 8.5% bond to November 5, 2026. Before then, transactions involving the blocked 50.1% CITGO Holding collateral remain prohibited absent separate authorization.
Primary sources: OFAC's September 18 Ethiopia and Russia update, Russia General License 131J, September 16 Venezuela update, Venezuela General License 5Z, and the ITAR final rule.
Immediate actions and watchlist
- Rebuild solar case matrices. Match origin, cell origin, producer, exporter, entry date and critical-circumstances status before assigning a rate or suspension date.
- Load the new order-stage rates. Update China L-lysine, rebar and Algeria wire rod controls; keep AD and CVD case numbers and deposits separate.
- Test ACE releases now. Validate Entry Type 13 logic for the September 22 deployment and budget the fiscal-year 2027 COBRA fees for October 1 entries.
- Use HTS Revision 19. Retain the two Canada proclamations and CBP Section 338 guidance with classification support files.
- Refresh restricted-party and license workflows. Remove reliance on the expired Ethiopia program, but confirm whether another sanctions authority still applies; calendar the Lukoil and Venezuela license dates.
FAQ
Are the solar AD/CVD orders in force?
No. Commerce issued final affirmative determinations, but permanent orders depend on affirmative USITC injury decisions. Case-specific provisional and suspension rules still matter in the interim.
Can the solar AD and CVD rates simply be added?
No. Deposit adjustments, subsidy offsets, producer/exporter combinations, provisional-measure gaps and order-stage instructions must be applied separately.
Does the Canada memorandum ban Canadian imports?
No. It directs agencies to pursue legally available federal civil-procurement restrictions. It does not itself create a customs import prohibition or publish a product list.
What did CBP correct for 9903.03.15?
CBP corrected the published F884 description. ACE rejects the exempt number 9903.03.15 unless the entry line also carries an appropriate dutiable Section 338 Chapter 99 number.
Does Ethiopia's delisting remove every compliance risk?
No. The E.O. 14046 program expired, but parties and transactions must still be screened under all other applicable sanctions, export-control and end-use authorities.
Primary sources
- Commerce: India solar cells final AD determination and companion final CVD determination — September 16, 2026.
- Commerce: Indonesia solar cells final AD determination and companion final CVD determination — September 16, 2026.
- Commerce: Laos solar cells final AD determination and companion final CVD determination — September 16, 2026.
- Commerce: China L-lysine AD/CVD orders — September 16, 2026.
- Commerce: rebar AD orders and rebar CVD orders — September 18, 2026.
- CBP CSMS #69941677 and CBP CSMS #69915041.
- White House: Restoring Reciprocity in Government Procurement — September 16, 2026.
- USITC: HTS Archive, Revision 19 and Modification Sources.
- OFAC: Ethiopia program expiration and Russia General License 131J — September 18, 2026.
Disclaimer: This publication provides general trade-compliance information and is not legal advice. Product scope, origin, producer/exporter identity, entry date, liquidation status, sanctions ownership, end use and agency instructions should be verified for each transaction.