The International Trade Administration has initiated an inquiry into whether crystalline silicon photovoltaic cells, whether or not assembled into modules, that are completed in Cambodia, Malaysia, Thailand, or Vietnam using parts and components from China are circumventing the AD and CV duty orders on such goods from China. If the ITA reaches an affirmative determination, subject goods could be hit with AD/CV duties.

The goods covered by the AD/CV duty orders on China are crystalline silicon photovoltaic cells, and modules, laminates, and panels consisting of crystalline silicon photovoltaic cells, whether or not partially or fully assembled into other products, including modules, laminates, panels, and building integrated materials. These items are currently classified in HTSUS subheadings 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, 8507.20.8010, 8507.20.8031, 8507.20.8041, 8507.20.8061, 8507.20.8091, 8541.42.0010, and 8541.43.0010.

The petition requesting this inquiry alleged that since the original orders were imposed U.S. imports of CSPV cells and modules from China have declined by 86 percent while imports from the subject third countries have increased by 868 percent and now account for almost all imports of the goods at issue.

For more information, please contact attorney Kristen Smith at (202) 730-4965.

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