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Scope of the Order
The merchandise covered by the order is modules, laminates and/or panels consisting of crystalline silicon photovoltaic cells, whether or not partially or fully assembled into other products, including building integrated materials. For purposes of the order, subject merchandise includes modules, laminates and/or panels assembled in China consisting of crystalline silicon photovoltaic cells produced in a customs territory other than China.
Subject merchandise includes modules, laminates and/or panels assembled in China consisting of crystalline silicon photovoltaic cells of thickness equal to or greater than 20 micrometers, having a p/n junction formed by any means, whether or not the cell has undergone other processing, including, but not limited to, cleaning, etching, coating, and/or addition of materials (including, but not limited to, metallization and conductor patterns) to collect and forward the electricity that is generated by the cell.
Excluded from the scope of the order are thin film photovoltaic products produced from amorphous silicon (a-Si), cadmium telluride (CdTe), or copper indium gallium selenide (CIGS).
Also excluded from the scope of the order are modules, laminates and/or panels assembled in China, consisting of crystalline silicon photovoltaic cells, not exceeding 10,000 mm2 in surface area, that are permanently integrated into a consumer good whose function is other than power generation and that consumes the electricity generated by the integrated crystalline silicon photovoltaic cells. Where more than one module, laminate and/or panel is permanently integrated into a consumer good, the surface area for purposes of this exclusion shall be the total combined surface area of all modules, laminates and/or panels that are integrated into the consumer good.
Further, also excluded from the scope of the order are any products covered by the existing antidumping and countervailing duty orders on crystalline silicon photovoltaic cells, whether or not assembled into modules, laminates and/or panels, from China.
Additionally, excluded from the scope of the order are solar panels that are: (1) Less than 300,000 mm2 in surface area; (2) less than 27.1 watts in power; (3) coated across their entire surface with a polyurethane doming resin; and (4) joined to a battery charging and maintaining unit (which is an acrylonitrile butadiene styrene (ABS) box that incorporates a light emitting diode (LED)) by coated wires that include a connector to permit the incorporation of an extension cable. The battery charging and maintaining unit utilizes high-frequency triangular pulse waveforms designed to maintain and extend the life of batteries through the reduction of lead sulfate crystals. The above-described battery charging and maintaining unit is currently available under the registered trademark “SolarPulse.”
Also excluded from the scope of the order are off-grid crystalline silicon photovoltaic panels without a glass cover with the following characteristics: (1) Total power output of 500 watts or less per panel; (2) maximum surface area of 8,000 cm2 per panel; (3) unit does not include a built-in inverter; (4) unit has visible parallel grid collector metallic wire lines every 2-40 millimeters across each solar panel (depending on model); (5) solar cells are encased in laminated frosted PET material without stitching; (6) the panel is encased in polyester fabric with visible stitching which includes a Velcro-type storage pocket and unit closure, or encased within a Neoprene clamshell (depending on model); and (7) includes LED indicator.
Merchandise covered by the order is currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under subheadings 8501.31.8000, 8501.61.0000, 8501.71.0000 8501.72.1000 8501.72.2000 8501.72.3000 8501.72.9000 8501.80.1000 8501.80.2000 8501.80.3000 8501.80.9000, 8507.20.8030, 8507.20.8040, 8507.20.8060, 8507.20.8090, 8541.40.6015, 8541.40.6020, 8541.40.6030, 8541.40.6035, 8541.42.0010, and 8541.43.0010. These HTSUS subheadings are provided for convenience and customs purposes; the written description of the scope of the order is dispositive.
Final Scope Rulings, Circumvention Determinations, and Changed Circumstance Determinations
| Record Type | Final Signature Date | Product Description | Decision | In Scope? | Scope Determination | HTS Change(s) | Scope Language Change(s) |
|---|---|---|---|---|---|---|---|
| Changed Circumstances Review | 07/18/2025 | Lutron - Small Off-Grid Panels | View Document | Yes | Commerce continues to find, pursuant to sections 751(d)(1) and 782(h)(2) of the Act and 19 CFR 351.222(g), that changed circumstances exist that warrant revocation of the Orders, in part. No interested party opposed this partial revocation. | ||
| Changed Circumstances Review | 06/22/2023 | Hello Tech June 2022 | View Document | No | Commerce is revoking, in part, the antidumping duty and countervailing duty orders on crystalline silicon photovoltaic products (solar products) from the People’s Republic of China (China) with respect to certain off-grid small portable crystalline silicon photovoltaic (CSPV) panels. | ||
| Scope Inquiry | 06/15/2022 | Solar Cells and Modules (HT Solar) | View Document | No | We recommend that the U.S. Department of Commerce (Commerce) determine that the solar cells and modules that are manufactured in the Republic of Turkey (Turkey) by HT Solar Enerji AS (HT Solar), and as described in HT Solar’s request for a scope ruling, are outside of the antidumping duty (AD) and countervailing duty (CVD) orders on certain crystalline silicon photovoltaic products (solar products) from the People’s Republic of China (China). | ||
| Changed Circumstances Review | 03/12/2021 | Memory Experts | View Document | No | Commerce is revoking, in part, the antidumping duty (AD) and countervailing duty (CVD) orders on crystalline silicon photovoltaic products from the People’s Republic of China (China) (Solar Products Orders) with respect to certain off-grid portable small panels. | ||
| Scope Inquiry | 01/23/2020 | Crystalline Solar Panels & Solar Cells (SunSpark) | View Document | No | Based on our analysis of SunSpark’s complete scope ruling request, we recommend determining that the photovoltaic products at issue are not covered by the scope of the Orders. | ||
| Changed Circumstances Review | 03/30/2017 | PulseTech April 2016 | View Document | No | The Department is revoking, in part, the Orders as to imports of certain solar panels that are incorporated in the battery charging and maintaining units described below. | ||
| Scope Inquiry | 11/12/2015 | Aireko Construction LLC | View Document | Yes | The Department determines that the solar modules assembled in the People's Republic of China ("PRC") with U.S.-origin solar cells and imported by Aireko Construction, LLC ("Aireko") that are the subject of this scope ruling request are within the scope of the antidumping duty and countervailing duty orders on certain crystalline silicon photo voltaic products ("Solar Products") from the PRC. | ||
| Scope Inquiry | 11/12/2015 | Certain Solar Panels (PulseTech) | Yes | The Department determines that the product falls within the scope of the Order. |

