A US buyer comparing solar tariffs in 2025 vs 2026 is usually trying to fix a stale spreadsheet. The supplier quote may still include an old Section 201 safeguard line. The broker may now need a Section 122 entry-date line. The 50% Section 301 layer may still be there. The AD/CVD file did not disappear. And a project that clears customs can still run into UFLPA or FEOC tax-credit review.
The main change is not that the US removed its tariff wall on Chinese solar panels. It did not. The change is that the 2026 file has different timing fields. Old safeguard assumptions need to be removed, temporary surcharge assumptions need to be added for the current window, and producer-specific duty support is still required.
This article answers only the 2025-vs-2026 change question. For the full current landed-cost model, see china-solar-panel-import-duties-2026. For the Section 301 layer, see section-301-solar-tariffs-china-2026. For Southeast Asian routes, see southeast-asia-solar-circumvention-duties-2026.
Quick Answer
US tariffs on Chinese solar panels in 2026 are not lower just because the old Section 201 solar safeguard expired. The core China-origin file still includes the 50% Section 301 solar-cell layer, producer-specific AD/CVD, UFLPA traceability, and FEOC/project eligibility checks. The new 2026 timing issue is the temporary Section 122 surcharge, which applies during its current window unless changed.
| Question | 2025 position | 2026 position |
|---|---|---|
| Section 301 on Chinese solar cells | 50% layer already central after the 2024 modification | Still a baseline 50% layer for China-origin solar cells, whether or not assembled into modules |
| Section 201 solar safeguard | Still appeared in some legacy tariff models | Expired on 2026-02-06 per USTR's 2026 Trade Policy Agenda |
| Section 122 surcharge | Not part of the normal 2025 solar spreadsheet | Temporary 10% surcharge window from 2026-02-24 to 2026-07-24 unless changed |
| China/Taiwan AD/CVD | Still live and producer-specific | Still live after USITC's 2026-05-27 sunset-review decision |
| Southeast Asia routes | Cambodia, Malaysia, Thailand, Vietnam cases moved toward final orders in 2025 | Producer/exporter rate support is now mandatory for those routes |
| UFLPA | Already a major solar traceability risk | Still a border admissibility file, not a tariff percentage |
| FEOC/PFE tax-credit risk | Became increasingly important for project finance | IRS/Treasury 2026 guidance makes material-assistance evidence a live project file |
- Buyer's rule: a 2025 tariff spreadsheet should not be reused for a 2026 shipment without checking entry date, Section 201 status, Section 122 window, AD/CVD rate support, and project-credit assumptions.
The 2025 Quote Audit
Start with the quote you already have. Many solar procurement teams do not need a new theory of US trade law; they need to find stale rows in an old quote.
Use this audit:
| Quote item | What to ask in 2026 |
|---|---|
| "Safeguard duty" | Is this an old Section 201 line that should no longer be in the model? |
| "China tariff" | Is this specifically Section 301, AD/CVD, Section 122, or a vague combined number? |
| "All duties included" | Which entry date, HTS line, producer, and AD/CVD rate does it assume? |
| "Made in Southeast Asia" | Which producer/exporter rate file supports the route? |
| "DDP to site" | Who is importer of record and who keeps the entry documents? |
| "Tax credit eligible" | Is there FEOC/PFE evidence, or only a sales statement? |
| "UFLPA compliant" | Is there polysilicon-to-module traceability, or only a supplier declaration? |
- Audit note: this often exposes the real issue. The supplier may be pricing a logistics promise, while the buyer needs a customs, traceability, and project-finance record.
Entry Date Decision Tree
For 2026, the entry date decides whether temporary measures belong in the model.
| Decision point | Buyer action |
|---|---|
| Entry before 2026-02-06 | Check whether Section 201 still appeared in the relevant entry file |
| Entry after 2026-02-06 | Do not keep Section 201 by habit; ask broker to confirm removal |
| Entry from 2026-02-24 through 2026-07-24 | Review Section 122 temporary surcharge unless changed or excluded |
| Entry after 2026-07-24 | Confirm whether Section 122 expired, changed, or was extended |
| Entry date uncertain | Keep a sensitivity line until logistics timing is firm |
- Timing note: "ship date" is not enough. The customs entry date can move if the vessel is delayed, documents are corrected, port congestion appears, or CBP requests more information. A serious quote should show which date controls the duty assumption.
What Did Not Change: Section 301 Stayed Central
The first thing that did not change is the 50% Section 301 solar-cell layer. The Federal Register notice implementing USTR's Section 301 modifications increased duties on Chinese solar cells, whether or not assembled into modules, to 50%.
That phrase still matters in 2026. A buyer should not assume that a finished module escapes the cell issue. A module is built from cells, and the tariff file moves backward into cell origin.
For a direct China-origin module quote, Section 301 remains the first visible wall. The supplier may argue that 2026 is different because some older solar safeguards ended. That does not remove the Section 301 layer.
The cleaner way to model it:
| Product route | Section 301 treatment to review |
|---|---|
| China-origin loose cells | 50% solar-cell layer is a baseline issue |
| China-origin cells assembled into modules | 50% layer remains because the rule covers cells assembled into modules |
| Non-China assembly using China-origin cells | Cell origin still needs review |
| Southeast Asian module with non-China cells | Section 301 may be less central, but AD/CVD, UFLPA, and FEOC still need review |
- Scope note: a supplier's "not Section 201 anymore" claim is incomplete. Section 201 and Section 301 are different files.
What Changed: Section 201 Expired
The clearest 2026 change is the end of the Section 201 solar safeguard. USTR's 2026 Trade Policy Agenda states that safeguard duties on crystalline silicon photovoltaic cells, modules, and large residential washers expired on 2026-02-06.
For buyers, that means an old spreadsheet may be wrong if it still includes a Section 201 solar safeguard line for a mid-2026 entry. Remove the line only after a broker confirms the product and entry date. But do not let a supplier use Section 201 expiration as proof that the US tariff wall is gone.
Section 201 was a global safeguard. Section 301 is a China-origin trade-action duty. AD/CVD is a producer/exporter trade-remedy file. They are not interchangeable.
| Tool | 2026 buyer status |
|---|---|
| Section 201 safeguard | Do not keep old line by habit; verify it expired for the planned entry |
| Section 301 China solar-cell layer | Still model for China-origin solar cells and cells assembled into modules |
| AD/CVD | Still producer-specific and route-specific |
| UFLPA | Still an admissibility file |
| FEOC/PFE | Still a project-value file |
- Practical mistake: using "Section 201 expired" as a shortcut for "US solar tariffs fell." The tariff stack changed, but it did not vanish.
Before And After: The Spreadsheet Rows
The cleanest way to see the change is to compare rows.
| Spreadsheet row | 2025 model | 2026 model |
|---|---|---|
| FOB module price | Supplier quote, often pre-rebate-change assumptions | Supplier quote after China's 2026 export rebate change and market repricing |
| Freight and insurance | Add to customs value | Still required |
| Section 201 | May appear depending on timing and product | Do not include for mid-2026 entries after expiration unless broker identifies a basis |
| Section 301 | 50% after 2024 modification | Still 50% for China-origin solar cells, whether or not assembled into modules |
| Section 122 | Usually absent | Add if entry falls in temporary 2026 window |
| AD/CVD | Producer-specific | Still producer-specific; do not use country label |
| Southeast Asia AD/CVD | Investigation/orders emerging around 2025 | Fully a route-file problem in 2026 procurement |
| UFLPA | Major traceability file | Still major; should be prepared before shipment |
| FEOC/PFE | Increasing finance concern | Explicit project-credit evidence file under 2026 guidance |
- Spreadsheet note: the buyer should preserve both versions. When a supplier says the price changed because "tariffs changed," the team can see whether the change is from actual duty law, supplier margin, freight, FOB pricing, route, producer rate, or project-credit evidence.
What A Broker Memo Should Say
A 2026 broker memo should not be a one-line "tariff checked" email. It should answer:
- product form and likely HTS classification
- importer of record
- planned entry date
- country of origin basis
- whether China-origin cells are involved
- Section 301 treatment
- Section 122 treatment for the entry window
- confirmation that Section 201 is not being applied, if appropriate
- AD/CVD scope and cash-deposit rate basis
- Southeast Asia route review if applicable
- documents the importer must retain
This memo becomes the bridge between procurement and customs. Without it, the buyer is trusting a quote that may not survive entry review.
What Changed: Section 122 Became A 2026 Timing Field
The new 2026 line is Section 122. The White House imposed a temporary 10% import surcharge under Section 122 effective 2026-02-24 through 2026-07-24 unless changed.
That makes entry date important. A purchase order signed in March, a shipment loaded in May, and an entry filed in July can sit inside different commercial assumptions. A serious 2026 duty model should have an entry-date field, not only a quote date.
Section 122 is smaller than AD/CVD in most China-origin solar examples. But it matters because older tariff guides often miss it, and because the surcharge compounds on top of an already expensive duty stack.
Use this rule:
| Date field | Why it matters |
|---|---|
| Quote date | Commercial negotiation date, not customs liability date |
| Ship date | Logistics planning date, not always duty date |
| Entry date | Determines whether a temporary surcharge applies |
| Placed-in-service date | Relevant for some tax-credit and project-value questions |
What Still Matters: AD/CVD Did Not Disappear
The USITC's 2026-05-27 sunset-review decision kept the China/Taiwan crystalline silicon photovoltaic product duty file alive. The Commission determined that revoking existing orders would likely lead to continued or recurring material injury.
For a buyer, this means 2026 is not a clean reset. The producer-specific AD/CVD question remains.
Ask:
- who is the legal producer?
- who is the exporter?
- is the company individually reviewed?
- what cash-deposit rate applies?
- what review period supports the rate?
- is Taiwan involved?
- is Southeast Asia involved?
- does the product match the order scope?
The highest-risk file is the one where the supplier gives only a brand name or country label. AD/CVD works at a more precise level than that.
Southeast Asia Changed The 2026 Buyer Question
Another change between 2025 and 2026 is that Southeast Asian routes became harder to treat as simple alternatives to China. Commerce's final determinations for Cambodia, Malaysia, Thailand, and Vietnam solar cells, whether or not assembled into modules, turned country labels into producer/exporter files.
For example, high-end combined AD/CVD exposure can reach about 3,521% for Cambodia, 972% for Thailand, 814% for Vietnam, and 250% for Malaysia. That does not mean every module from those countries carries the maximum rate. It means the importer needs exact producer and exporter support before using the route.
This is where southeast-asia-solar-circumvention-duties-2026 fits into the cluster. The main 2025-vs-2026 change is not "Southeast Asia no longer works." It is "Southeast Asia now requires a documented rate file."
UFLPA And FEOC Became Harder To Ignore
UFLPA was already important before 2026, but buyers now make a bigger mistake when they treat it as optional. A shipment can pay the right duties and still be detained if the polysilicon-to-module traceability file is weak. For that workflow, use uflpa-solar-panel-import-checklist.
FEOC and prohibited foreign entity rules are a different problem. They do not decide whether the shipment clears customs. They decide whether a project or manufacturer can rely on clean-energy tax-credit value. IRS/Treasury 2026 guidance on material assistance from prohibited foreign entities makes this a live file for 45Y, 48E, and 45X projects. For that workflow, use feoc-solar-buyers-tax-credit-risk.
The 2026 buyer should separate the files:
| File | 2026 question |
|---|---|
| Tariff file | What do we pay at entry? |
| UFLPA file | Can the goods enter? |
| FEOC/PFE file | Can the project preserve credit value? |
| Finance file | Will the lender, tax equity provider, insurer, and customer accept the equipment package? |
2025 Spreadsheet Cleanup Checklist
If your team is still using a 2025 tariff spreadsheet, clean it before using it for 2026 shipments.
| Spreadsheet row | 2026 action |
|---|---|
| Section 201 safeguard | Remove or mark expired after broker confirms entry date and product scope |
| Section 301 China solar cells | Keep the 50% line where China-origin cells apply |
| Section 122 | Add a temporary 10% entry-date line for the current window |
| AD/CVD | Replace generic country rate with producer/exporter rate support |
| Southeast Asia route | Add country-specific Commerce case review |
| UFLPA | Add traceability readiness field |
| FEOC/PFE | Add project-credit review field if 45Y, 48E, or 45X matters |
| Contract | Add who bears rate changes, detention, and document failure |
- Cleanup note: the better spreadsheet is not longer because compliance people like complexity. It is longer because the 2026 buyer file has more gates.
Supplier Email Template
Use a simple request before accepting a 2026 quote:
Ask the supplier: "We are reviewing this solar module quote for a 2026 US entry. Please confirm the planned producer, exporter, cell producer, module assembly site, country of origin, proposed HTS classification, AD/CVD rate support, Section 301 assumption, Section 122 entry-date assumption, UFLPA traceability file, and FEOC/PFE support if the project claims 45Y, 48E, or 45X value. Please also confirm that no producer, exporter, cell source, or module assembly site will be substituted without written approval."
That email is not a legal opinion. It is a filter. A supplier that cannot answer it is not ready for a US-bound credit-sensitive shipment.
Red Flags In 2026 Quotes
| Red flag | Why it matters |
|---|---|
| Quote still says "Section 201 solar duty" with no date | It may be copied from a 2025 file |
| Quote says "tariff included" but gives no rate schedule | Buyer cannot tell whether Section 301, Section 122, and AD/CVD are modeled |
| Supplier quotes "not China" without producer/exporter details | Southeast Asia routes can carry their own AD/CVD exposure |
| Cell producer is missing | Section 301 and AD/CVD review often depend on cell origin and producer |
| DDP seller refuses entry records | Buyer may lack audit and project-finance evidence |
| UFLPA file is promised after shipment | Detention response will be late |
| FEOC statement is one sentence | Tax-credit projects need deeper supplier and component evidence |
Three Buyer Scenarios
| Scenario | What changed from 2025 to 2026 |
|---|---|
| Direct China-origin module importer | Section 301 and AD/CVD remain central; Section 201 may be removed; Section 122 may apply during the current window |
| Southeast Asia module route | Country label is not enough; producer/exporter rate support is mandatory |
| US project relying on tax credits | Customs cost is only one part of the decision; FEOC/PFE evidence can determine project value |
FAQ
Did US tariffs on Chinese solar panels go down in 2026?
Not in the way many buyers hope. The Section 201 safeguard expired on 2026-02-06, but the 50% Section 301 layer, AD/CVD, UFLPA, and FEOC/project review remain important. A temporary Section 122 surcharge also applies during its current 2026 window unless changed.
Is the Section 201 solar tariff still active in 2026?
No for the mid-2026 model used here. USTR's 2026 Trade Policy Agenda says the safeguard duties on crystalline silicon photovoltaic cells and modules expired on 2026-02-06. A broker should still confirm the product and entry date before removing a line from a live entry model.
What is the current US tariff stack on solar panels from China in 2026?
For direct China-origin cells and modules, start with the 50% Section 301 layer. Then review temporary Section 122 for the entry date, producer-specific AD/CVD, UFLPA traceability, and FEOC or prohibited foreign entity project risk if tax credits matter.
Does a Southeast Asian solar module avoid the China tariff problem in 2026?
Not automatically. Cambodia, Malaysia, Thailand, and Vietnam routes require producer/exporter AD/CVD review. The buyer must also check cell origin, UFLPA traceability, and project eligibility.
What should I ask my supplier for in 2026 that I may not have asked in 2025?
Ask for the planned US entry date, exact producer/exporter names, cell origin, AD/CVD rate support, UFLPA traceability, FEOC/PFE certification support if credits matter, and contract terms covering duty changes or false representations.
Methodology And Source Notes
This article compares the 2025 and 2026 US solar tariff file for buyer use. It uses USTR's 2026 Trade Policy Agenda for the Section 201 expiration date, the Federal Register Section 301 modification notice for the 50% China solar-cell layer, the White House Section 122 proclamation for the temporary 2026 surcharge window, the USITC 2026 sunset-review decision for AD/CVD continuity, Commerce materials for Southeast Asian AD/CVD route risk, CBP/DHS materials for UFLPA traceability, and IRS/Treasury guidance for FEOC/PFE project risk. It is date-stamped 2026-06-13 because entry-date windows, administrative reviews, and tax-credit guidance can change.
Related Entries
- china-solar-panel-import-duties-2026
- section-301-solar-tariffs-china-2026
- southeast-asia-solar-circumvention-duties-2026
- uflpa-solar-panel-import-checklist
- feoc-solar-buyers-tax-credit-risk
- importing-solar-panels-china-us-2026
By China Made & Tech Team. Independent English field guide to China's niche hardware brands, hidden champions, founders, factory towns, and supplier clusters.