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Section 201 Quota, tariff or import license fee allow continuous shipment to US

The US International Trade Commission (USITC) had a meeting on October 31st (US time zone). Since the commissioners of ITC proposed different suggestions for the remedy measures, the impact from the “Section 201” case is not completely clear yet. But it seems that the ITC prefers the combination of import quota and tariff/import license fees. Manufacturers can start to see what can be the ways of responding.

The overall situation won’t be clearer until the ITC officially comes up with suggestions and presents the suggestions to President Trump on November 13th. By then, the White House will have sixty days to decide whether they will take ITC’s proposal or make a different decision.

The opinions suggested by the four commissioners are as below:

Among the four commissioners, Broadbent’s proposal of an import quota of 8.9GW and an import license fee of only US$ 0.01/W has the least impact on the industry. With the 8.9GW import Quota plus the additional capacities around 6GW that were not affected by the “Section 201” case, the US demand can almost stay flat and won’t decline if the import license fee can be processed successfully.

But the result may end up with the import quota and tariff solution proposed by the other three members. Different tax rates will be imposed on cell and module imports. The tax rate will decline year by year in the next four years.

PV InfoLink Point of View

PV InfoLink believes that if shipping Chinese modules to the US, the cost reached US$ 0.28-0.30/W for 60pcs 270W and 72pcs 320-325W conventional multi-Si modules that use diamond wire (DW) wafers with the additive or wet etching methods. If adding the total tax rate of 60% from the “Section 201” case and the anti-dumping and countervailing duty rate, the minimum cost for modules to ship to the US reached US$ 0.45-0.48/W, US$ 5 cents higher than the current spot price of US$ 0.41-0.43/W in the US.

The original cost was US$ 0.34-0.35/W for mono-Si PERC modules. After taking the tax rate into account, it will increase to US$ 0.55/W, which is still in the acceptable range of US$ 0.5-0.6/W. Adding an ITC tax rate of 30% onto the N-type module cost of US$ 0.5-0.8/W is only equal or slightly higher than the current prices in the US regions. Therefore, N-type market share will shrink significantly. PERC will be the option with better profits among all other products. The ratio of PERC product shipping to the US will increase.

ITC’s decision will have limited effect on the capacities in Southeast Asia because there’s no need to count the anti-dumping and countervailing duties.

However, if calculating from a tax rate of 30% for cells, shipping cells directly to the US or having them assembled in countries that don’t require ITC tax rate is also one of the options to ship to the US. The multi-Si cell cost will only reach US$ 0.17/W next year, but after taking 30% tax rate into account, the cost will be US$ 0.22/W. After the multi-Si cell being assembled into a module in Singapore or other waiver countries, it will cost only US$ 0.42/W. Consequently, module capacity expansion in waiver countries like Singapore is another option too.

To conclude all of the above, most manufacturers will not choose to build factories in the US. Therefore, the largest variable lies in the quota allocation. It appears that although members of ITC have different quota methods, there will be at least 6-8GW of installation in the US (include capacities in countries that do not require a tax rate and import quota).

ITC final decision’s impact on the market

1.Manufacturers will witness lower tax rates and costs year by year. It’s not necessary for them to build factories in the US. However, waiver countries can still expand module capacities at the existing factories.

2.Capacities in Southeast Asia still have the advantages since they are not imposed the anti-dumping and countervailing duties.

3.In the form of tax rate, the lower the cost, the more room to ship to the US. This will accelerate manufacturers’ implementation of DW multi-Si wafers with additive or wet etching black silicon methods. For mono-Si products, it will be more urgent to lower wafer prices. The market share of N-type high-efficiency products with higher costs will be largely replaced by low-cost products.

4.President Trump will visit China in November right before ITC report is presented to him. All the topics and negotiation discussed with China may affect the final decision of the “Section 201” case.

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