Intensifying U.S. tariff pressure reshapes global supply chains

In recent years, U.S. trade policies on PV products have become increasingly complex and characterized by high uncertainty. Given the overlapping impact of multiple tariff regimes and regulatory measures across both upstream and downstream segments, global PV enterprises seeking to expand their presence in the U.S. face not only tariff-related barriers but also heightened challenges in supply chain compliance and risks arising from potential policy fluctuations.
 

U.S. tightens control on PV upstream amid ongoing Section 232 investigation

After extending Section 301 tariffs to Chinese polysilicon and wafers in 2024, the U.S. launched its first Section 232 investigation into imports of polysilicon and its derivatives in July 2025. While the investigation primarily targets imported polysilicon, InfoLink’s research indicates that numerous manufacturers and industry associations have actively lobbied U.S. authorities to expand the scope to include wafers and even downstream products such as cells and modules. Some stakeholders have even proposed that Section 232 adopt an import quota mechanism, with punitive tariff rates imposed on volumes exceeding the quota. This suggests that the Section 232 investigation may eventually extend across the entire PV supply chain, though detailed measures remain subject to official announcements.

For upstream PV products, if the Section 232 measures are implemented, they would likely reduce the prevailing price gap between U.S. and Chinese polysilicon. However, according to InfoLink’s statistics, the U.S. has yet to commission any wafer capacity as of September 2025, leaving its domestic market still reliant on wafer imports from Southeast Asia in the near term. Over the medium to long term, if Section 232 tariffs are coordinated with federal PV subsidy programs, they could support the gradual establishment of U.S. domestic polysilicon and wafer capacity, reinforcing the independence of the U.S. PV supply chain.
 

PV cell supply pressures persist amid looming new AD/CVD round

In April 2025, the U.S. issued final AD/CVD rulings on the four Southeast Asian countries—Cambodia, Thailand, Malaysia, and Vietnam—rendering cell exports from these markets to the U.S. economically unviable. In the aftermath, regions with relatively sufficient capacity, such as Indonesia and Laos, have gradually emerged as new centers of supply for the U.S. However, reciprocal tariffs on Laos and India, coupled with the U.S. decision in August 2025 to initiate a new round of AD/CVD investigations targeting Indonesia, Laos, and India, have further exacerbated risks to cell supply.

As of September 2025, U.S. domestic cell annual capacity is only about 2 GW, insufficient to meet demand from the module segment. If downstream players are unable to absorb the higher production costs brought by new tariffs, and cell capacity outside of China and Southeast Asia has yet to scale up, the cell supply gap in the U.S. will widen further, potentially constraining overall PV demand due to disrupted supply.

In response, some PV manufacturers are shifting capacity to the Middle East and Africa, where tariff impacts are lower and capacity is less concentrated. This trend reflects not only a short-term hedge but may also serve as a key driver of global capacity reallocation, accelerating supply chain restructuring.
 

Tariffs and compliance risks are forcing manufacturers to take a cautious approach to capacity planning

Under the America First agenda, U.S. restrictions on foreign PV products have intensified. Alongside AD/CVD, Section 232 investigations, and reciprocal tariffs, the One Big Beautiful Bill Act (OBBBA), passed in July 2025, imposes strict supplier compliance and localization requirements. In response, Chinese manufacturers expanding overseas and targeting the U.S. market are adjusting their overseas subsidiary equity structures and requiring raw material sourcing to be compliant to meet higher entry thresholds of the U.S.

In the long term, competition in the U.S. PV market is shifting from cost advantage to compliance and localization. Policies are driving manufacturers to invest more in compliance while restricting the use of third-country investment structures. As a result, many U.S. utility-scale project developers now favor domestic supply despite higher module prices and less advanced technology, prioritizing reduced policy risks and uncertainties.

Overall, the U.S. market is entering a policy-driven restructuring phase. Only PV manufacturers that can gain deep insight into U.S. policy directions, manage tariff risks, accelerate global expansion, and meet stringent compliance requirements will be able to stand out in this increasingly constrained market.