Solar Tariffs 2024: SEGA, Section 201, and the Bifacial Exemption Saga

Published June 15, 2024 — PES Supply Trade Policy Analysis

The first half of 2024 brought the most significant upheaval in U.S. solar trade policy since the Section 201 safeguard tariffs were first imposed in 2018. A cascade of actions — an antidumping and countervailing duty (AD/CVD) petition targeting four Southeast Asian nations, the revocation of the bifacial module exemption, the expiration of a two-year tariff moratorium, and a doubling of Section 301 tariffs on Chinese solar cells — collectively reshaped the cost structure of every module imported into the United States.

For installers and contractors, understanding these developments is essential for accurate project pricing, supply chain planning, and compliance with domestic content requirements. PES Supply tracks trade policy across our 50,000+ SKUs from 169 authorized brands to help you navigate an increasingly complex procurement landscape. This article breaks down the key tariff actions, their timeline, and practical strategies for managing their impact.

The Southeast Asian Tariff Investigation (SEGA)

On April 25, 2024, a group of U.S. solar manufacturers — including Hanwha Qcells, First Solar, Heliene, Suniva, Silfab, Crossroads Solar, Mission Solar, and Auxin Solar — filed an antidumping and countervailing duty (AD/CVD) petition with the U.S. Department of Commerce and the U.S. International Trade Commission against crystalline silicon solar cells and modules from Cambodia, Malaysia, Thailand, and Vietnam (collectively referred to as CMTV) ([pv magazine USA](https://pv-magazine-usa.com/2024/05/22/market-impacts-from-the-recent-flurry-of-solar-policy-actions/)).

This petition — sometimes referred to in industry shorthand as the Southeast Asia Global Alliance (SEGA) tariff action — targeted the four countries that collectively account for approximately 40% of global solar module production capacity outside of China ([Deutsche Welle](https://www.dw.com/en/eus-solar-plans-in-se-asia-caught-in-us-china-trade-war/a-70131486)). The petitioners alleged that Chinese-owned manufacturers operating in these countries were circumventing existing U.S. tariffs on Chinese solar products by completing assembly in Southeast Asia.

How the Investigation Works

The AD/CVD process involves two key determinations:

• Countervailing duty (CVD) preliminary determination: Originally due in September 2024, the deadline was postponed to September 27, 2024. On October 1, 2024, the Department of Commerce issued its preliminary CVD determination, finding that countervailable subsidies existed for producers in Vietnam, Malaysia, Thailand, and Cambodia ([NREL](https://docs.nrel.gov/docs/fy25osti/92257.pdf)).
• Antidumping (AD) preliminary determination: Originally due in November 2024, the deadline was postponed to November 27, 2024.

Historically, AD/CVD tariffs have ranged as high as 50% to 250% of the cost of shipped goods ([pv magazine USA](https://pv-magazine-usa.com/2024/05/22/market-impacts-from-the-recent-flurry-of-solar-policy-actions/)). The petitioners also filed a request for a finding of critical circumstances in the Thailand and Vietnam investigations, which could result in collection of duties retroactive to 90 days prior to the preliminary determinations ([SEIA](https://seia.org/research-resources/solar-market-insight-report-q3-2024/)).

Scope of the Investigation

The investigation covers modules made in the four targeted countries using cells of the same origin, as well as modules from other nations that include cells produced in CMTV countries. Critically, modules assembled in CMTV countries from cells made elsewhere are not affected — a distinction that benefits Chinese-funded manufacturers with vertically-integrated, non-Chinese supply chains ([pv magazine USA](https://pv-magazine-usa.com/2024/09/24/the-u-s-is-building-a-solar-trade-wall/)).

This scope distinction created significant supply chain restructuring. Some manufacturers shifted production to Indonesia and Laos, which currently do not face U.S. tariffs ([Deutsche Welle](https://www.dw.com/en/eus-solar-plans-in-se-asia-caught-in-us-china-trade-war/a-70131486)). By August 2024, Bloomberg reported that some U.S. firms were lobbying for tariffs as high as 272% on all solar imports from the four nations.

The Bifacial Module Exemption: A Saga in Five Acts

The bifacial solar module exemption from Section 201 safeguard tariffs is one of the most litigated trade policy issues in the history of the U.S. solar industry. Its reinstatement and revocation cycle directly affected the cost of 98% of all imported solar modules. Here is the complete timeline:

Timeline of the Bifacial Exemption

Date	Action	Tariff Rate
February 2018	Section 201 safeguard tariffs imposed on CSPV cells and modules	30%
June 2019	USTR grants exclusion for bifacial modules	Exempt
October 2020	Trump Administration revokes bifacial exclusion (Proclamation 10101)	18%
November 2021	U.S. Court of International Trade reinstates bifacial exclusion	15%
February 2022	President extends Section 201 safeguard; bifacial modules excluded	14.25%
February 2024	USITC files midterm report; Hanwha Qcells petitions to revoke exclusion	14.25% (exempt)
May 16, 2024	Biden Administration announces plan to remove bifacial exclusion	14.25%
June 26, 2024	Bifacial exclusion officially revoked	14.25% (now applies)

The revocation was driven by a petition from Hanwha Qcells, supported by First Solar, Heliene, Suniva, Silfab, Crossroads Solar, Mission Solar, and Auxin Solar. The Biden Administration stated that the bifacial exclusion had "undercut the effectiveness of the safeguard measure" ([Solar Power World](https://www.solarpowerworldonline.com/2024/05/bifacial-solar-modules-lose-tariff-exemption-after-biden-reverses-course/)).

The U.S. International Trade Commission documented that the two-year tariff holiday ended as scheduled on June 6, 2024, and producers that had been found to be circumventing the CSPV orders on China became subject to duties under those orders ([USITC](https://www.usitc.gov/publications/701_731/pub5517.pdf)). The Administration provided a limited safeguard: importers with pre-existing contracts for bifacial modules to be delivered within 90 days of the exclusion removal could certify those contracts to continue using the exemption for that period ([USTR](https://ustr.gov/sites/default/files/2024SolarSafeguardBifacialExclusion.prc.ANNEXES%20FINAL.pdf)).

SEIA opposed the revocation, arguing it would increase costs for commercial, industrial, and utility-scale solar projects. Industry analysis estimated the reinstated tariff would increase project costs by 1% to 2% ([pv magazine USA](https://pv-magazine-usa.com/2024/05/22/market-impacts-from-the-recent-flurry-of-solar-policy-actions/)).

Section 201 Safeguard Tariffs: The Foundation

The Section 201 safeguard tariffs, first imposed in February 2018 under President Trump, remain the foundational trade measure affecting imported crystalline silicon photovoltaic (CSPV) cells and modules. The tariffs were extended for a second four-year period in February 2022 and are scheduled to expire in February 2026 ([DOE](https://www.energy.gov/cmei/systems/overview-trade-and-policy-measures-us-solar-manufacturing)).

Current Section 201 Structure

Component	Tariff Rate	Notes
CSPV modules	14.25% ad valorem	Annual rate reductions scheduled through 2026
CSPV cells (within TRQ)	0% (duty-free)	First 12.5 GW annually (raised from 5 GW in August 2024)
CSPV cells (above TRQ)	14.25% ad valorem	Applies to imports exceeding the tariff-rate quota
Bifacial modules	14.25% (as of June 2024)	Exemption revoked; previously exempt since November 2021
Thin-film modules	Exempt	CdTe, a-Si, CIGS technologies excluded

According to the USTR's 2025 Trade Policy Agenda and 2024 Annual Report, Section 201 provides a procedure whereby the President may grant temporary import relief to a domestic industry if increased imports are a substantial cause of serious injury. Relief may be granted for an initial period of up to four years, with the possibility of extension to a maximum of eight years ([USTR](https://ustr.gov/sites/default/files/files/reports/2025/2025%20Trade%20Policy%20Agenda%20WTO%20at%2030%20and%202024%20Annual%20Report%2002282025%20--%20FINAL.pdf)).

On August 1, 2024, the President increased the cell tariff-rate quota from 5 GW to 12.5 GW, allowing more duty-free cell imports for domestic module assembly. By October 28, 2024, more than 9.4 GW (75% of the TRQ) of cells had been imported under the raised quota ([NREL](https://docs.nrel.gov/docs/fy25osti/92257.pdf)). The USITC's Year in Trade 2024 report confirmed that the President revoked the exclusion for bifacial modules and raised the cell TRQ through Proclamation 10790, effective August 1, 2024 ([USITC](https://www.usitc.gov/publications/332/pub5673.pdf)).

Section 301 Tariffs on China: Doubled in 2024

On May 23, 2024, President Biden announced the elevation of U.S. import tariffs on solar cells and panels from China from 25% to 50%, citing unfair business practices by Chinese companies ([Reuters](https://www.reuters.com/business/energy/us-solar-builders-brace-higher-costs-biden-hikes-tariffs-2024-05-23/)). While direct imports from China had already been limited by existing tariffs, the increase signaled a hardening of U.S. trade policy toward Chinese solar manufacturing.

In December 2024, the U.S. Trade Representative extended Section 301 tariffs further, doubling the rate on solar polysilicon and placing wafers on the Section 301 tariff list for the first time — both now subject to a 50% tariff if imported from China ([pv magazine USA](https://pv-magazine-usa.com/2024/12/12/u-s-doubles-solar-polysilicon-and-wafer-tariffs-on-china/)). The White House stated that "China has used unfair practices to dominate upwards of 80 to 90% of certain parts of the global solar supply chain and is trying to maintain that status quo."

However, the Administration also established a process allowing stakeholders to request temporary exclusion from Section 301 duties for certain solar manufacturing equipment, effective October 15, 2024 ([USTR](https://ustr.gov/sites/default/files/files/reports/2025/2025%20Trade%20Policy%20Agenda%20WTO%20at%2030%20and%202024%20Annual%20Report%2002282025%20--%20FINAL.pdf)). This carveout recognized that domestic manufacturing capacity for certain equipment remains insufficient.

Impact on Module Pricing

The combined effect of these trade actions had an immediate impact on module pricing. Anza, a solar and energy storage supply chain platform aggregating data from 95% of the U.S. solar module supply, reported the first module price increase since late 2022 in its Q2 2024 Pricing Insights Report ([pv magazine USA](https://pv-magazine-usa.com/2024/06/12/solar-module-prices-increase-for-first-time-in-years-anza-reports/)).

Key pricing observations from 2024:

Pricing Metric	Value	Source
Median module price (Feb 2024)	$0.279/W	Anza Q2 Report
Median module price (May 2024)	$0.25/W	Anza Q2 Report (11% decrease)
Price increase (May 2024)	~2%	First increase since late 2022
DDP US TOPCon spot (Nov 2024)	$0.285/W	pv magazine / OPIS
FOB China TOPCon (Nov 2024)	$0.087/W	pv magazine / OPIS

Clean Energy Associates (CEA) noted that while there was "no direct market impact" from the AD/CVD determination itself, the threat of tariffs was causing prices to increase, contracts to be re-negotiated, and procurement decisions to be delayed. Project timelines were being pushed back, particularly for projects planned for construction in 2025 ([pv magazine USA](https://pv-magazine-usa.com/2024/05/22/market-impacts-from-the-recent-flurry-of-solar-policy-actions/)).

As Anza CEO Mike Hall stated: "After years of record low pricing, we're seeing the market start to rebound as domestic manufacturers have less pricing pressure from foreign producers that are subject to tariffs. We're expecting to see this upward price trend continue from here, making it critical for new projects to consider current pricing and potential tariff impacts when sourcing materials" ([pv magazine USA](https://pv-magazine-usa.com/2024/06/12/solar-module-prices-increase-for-first-time-in-years-anza-reports/)).

Installer Supply Chain Strategies

Given the tariff landscape, installers and contractors should adopt the following strategies to protect project economics:

1. Diversify Sourcing Regions

Relying on modules from a single country or region creates concentrated tariff risk. The CMTV investigation demonstrates how quickly a sourcing region can become subject to new duties. Installers should evaluate suppliers across multiple countries of origin, including:

• Domestically manufactured modules: Qcells (Georgia), Silfab (Washington/South Carolina), Mission Solar (Texas), First Solar (Ohio/Arizona) — browse our solar panels collection.
• Non-CMTV Southeast Asian sources: Indonesia and Laos currently do not face U.S. AD/CVD tariffs, though this could change.
• Exempt countries: Cambodia was exempt from Section 201 under the developing country exception, though it is now subject to the AD/CVD investigation.
• Thin-film modules: CdTe and other thin-film technologies are exempt from Section 201 tariffs entirely.

2. Understand BOM Requirements

The anti-circumvention ruling stipulated that products from CMTV nations could avoid tariffs by using non-Chinese wafers and meeting module bill-of-materials (BOM) conditions. This benefits Chinese-funded manufacturers with vertically-integrated, non-Chinese supply chains. Installers should request detailed BOM documentation from suppliers to verify tariff exposure ([pv magazine USA](https://pv-magazine-usa.com/2024/09/24/the-u-s-is-building-a-solar-trade-wall/)).

3. Plan for Domestic Content Bonus Credits

The Inflation Reduction Act's domestic content bonus credit requires that structural construction components be 100% U.S.-manufactured, while "manufactured products" must include domestic content for 40% of cost (increasing to 55%). Even projects using trackers with a high portion of domestic content will typically need domestic cells or First Solar modules to qualify, and these remain in limited supply ([pv magazine USA](https://pv-magazine-usa.com/2024/05/22/market-impacts-from-the-recent-flurry-of-solar-policy-actions/)).

4. Lock In Pricing with Forward Contracts

Given the upward price trend and ongoing tariff uncertainty, securing forward contracts for module supply can protect project economics. The bifacial exemption revocation included a 90-day grandfathering period for pre-existing contracts, highlighting the value of documented purchase agreements ([USTR](https://ustr.gov/sites/default/files/2024SolarSafeguardBifacialExclusion.prc.ANNEXES%20FINAL.pdf)).

5. Evaluate Cell TRQ Utilization

With the cell tariff-rate quota raised to 12.5 GW, domestic assemblers have greater access to duty-free cells. By October 2024, 75% of the TRQ had been consumed. Installers working with domestic assembly partners should monitor TRQ utilization rates, as the quota may be exhausted before year-end ([NREL](https://docs.nrel.gov/docs/fy25osti/92257.pdf)).

The Road Ahead

The Section 201 safeguard tariffs are scheduled to expire in February 2026, but the AD/CVD investigations and Section 301 tariffs will continue to shape the trade landscape regardless. SEIA noted in its Q3 2024 Solar Market Insight report that there is sufficient cell and module production capacity from multiple sources not subject to the proposed tariffs — production outside the targeted countries, expanding domestic production, and thin-film modules — suggesting that tariff impacts on overall solar deployment will be modest ([SEIA](https://seia.org/research-resources/solar-market-insight-report-q3-2024/)).

However, the uncertainty itself has a cost. The threat of retroactive duties, re-negotiated contracts, and delayed procurement decisions creates friction throughout the supply chain. Installers who proactively diversify their sourcing, document BOM compliance, and maintain relationships with multiple suppliers will be best positioned to weather the ongoing trade turbulence.

PES Supply can help you navigate these challenges. With 50,000+ SKUs from 169 authorized brands, including domestically manufactured modules from Qcells, Silfab, Mission Solar, and First Solar, we offer the product breadth and trade expertise to support compliant, cost-effective procurement. Explore our solar panels, inverters, racking and mounting, and balance of system collections for your next project. Standard delivery is 7-10 business days.

Key Sources

• USITC, Crystalline Silicon Photovoltaic Cells Investigation (Pub. 5517) — usitc.gov
• USITC, The Year in Trade 2024 (Pub. 5673) — usitc.gov
• USTR, 2025 Trade Policy Agenda and 2024 Annual Report — ustr.gov
• USTR, Bifacial Exclusion Annexes — ustr.gov
• SEIA, Solar Market Insight Q3 2024 — seia.org
• pv magazine USA, Market Impacts from Solar Policy Actions — pv-magazine-usa.com
• Reuters, US Solar Builders Brace for Higher Costs — reuters.com
• NREL, Fall 2024 Solar Industry Update — docs.nrel.gov
• DOE, Overview of Trade and Policy Measures for U.S. Solar Manufacturing — energy.gov