Trade barriers on PV bill of materials (BoMs) emerge as a key issue amid accelerating globalization

In recent years, while the global PV industry has seen rapid growth, it has also encountered trade barriers with increasing frequency. For many companies, Antidumping and Countervailing Duties (AD/CVD) have become familiar terms—dating back to the U.S. investigation into Chinese PV products in 2011, and followed by similar measures introduced in Europe, India, and other regions. As a result, PV enterprises expanding overseas are often exposed to policy risks.

Traditionally, AD/CVD measures were directed mainly at modules and cells. However, as PV bill of materials (BoMs) account for a growing share of module costs and play an increasingly critical role in the supply chain, products such as PV glass, aluminum frames, and encapsulants are now subject to AD/CVD investigations and restriction lists in non-China markets.

This trend cannot be overlooked by PV industry players. For BoM manufacturers, it signals a growing market complexity. In the past, these firms could simply expand alongside module makers. Today, they must directly address overseas policy risks and plan proactively in terms of strategies, market positioning, and compliance. For buyers, procurement decisions are no longer based solely on price and quality; supply chain stability and tariff risks must also be carefully considered. As key components of PV modules, BoMs—through changes in their supply-demand dynamics and evolving policies—are quietly reshaping the global PV market landscape.
 

AD/CVD scope on BoMs has gradually expanded since 2024 

In the past, AD/CVD measures on PV BoMs mainly targeted PV glass and encapsulants. In recent years, however, their scope has broadened to include backsheets, junction boxes, and aluminum frames. The chart below summarizes AD/CVD investigations and rulings on BoMs initiated over the past year. India’s AD investigation on encapsulants, along with the AD/CVD investigations on glass in both India and the EU, represent continuations of earlier AD/CVD measures.

In May 2025, Türkiye (Turkey) launched its first AD investigation on BoMs, focusing on junction boxes and aluminum frames. InfoLink has outlined the corresponding investigation procedures for reference, while the final implementation of these policies remains subject to further monitoring.

From a regional perspective, India’s PV market has been expanding rapidly while implementing highly protectionist policies to safeguard its domestic industry. In addition to the steep tariffs imposed on modules and cells, Indian manufacturers are actively lobbying their government to impose further restrictions on imported BoMs, thereby creating greater opportunities for local production. In the U.S., the anti-circumvention investigation into the four Southeast Asian countries (Thailand, Vietnam, Malaysia, and Cambodia) has also extended to some BoMs. Meanwhile, the EU has imposed substantial AD duties on Chinese PV glass, which once severely constrained Chinese exports and remains in effect today.

Overall, the U.S. and EU have placed BoMs under strict regulatory scrutiny, while India continues to emphasize protectionist measures to support localization. This indicates that the overseas operating environment for PV BoM companies is likely to become more complex and challenging going forward.
 

Bill of materials (BoM) has become a focus in AD/CVD measures

Unlike previous AD/CVD measures that mostly targeted main PV materials, BoMs are increasingly drawing attention due to the following factors.

• Rising share of BoM costs: With polysilicon prices falling sharply, module cost structures are shifting. Glass, frames, encapsulants, junction boxes, ribbons, backsheets, and silver paste now make up nearly 60% of total costs, becoming a major driver of module costs.
  

• Supply chain dependence: Global PV BoM capacity is highly concentrated in China, leaving many markets reliant on Chinese imports. Once trade frictions escalate, this reliance can trigger “unfair competition” claims and drive local companies to push their governments to adopt protectionist measures.

• Tight linkage with main materials: BoMs are usually shipped alongside cells and modules, making them possibly affected by AD/CVD investigations on cells and modules. For instance, prior U.S. anti-circumvention investigations traced the sourcing and origin of BoMs, thereby extending the scope of trade barriers. 
   

PV globalization accelerates; BoMs face risks and opportunities

With the globalization of the PV supply chain, trade barriers are progressively extending from core products to BoMs. AD/CVD investigations and policy restrictions in non-China markets are increasingly encompassing PV BoMs.

For cell and module makers, supply chain stability and tariff risks are critical. Overlooking them may lead to a passive stance in global competition. Proactive planning in strategy, markets, and supply chains is essential to ensure stability and seize future opportunities. AD/CVD measures bring risks but also reshape industry competition.

For PV BoM manufacturers, this presents an opportunity for a “forced upgrade”: those who build overseas capacity fastest can secure a first-mover advantage, those who develop differentiated products first can break through trade barriers, and those who best align with policy shifts can maintain stability amid market volatility.

Amid escalating AD/CVD measures, BoM manufacturers must go beyond product strength to adopt global strategies and robust risk management. To navigate this trend, enhancing compliance in advance and proactively positioning in markets and supply chains are essential to sustain growth in the intensifying global competition.

For a deeper understanding of global supply-demand dynamics, price trends, and potential trade barriers in PV BoMs, InfoLink’s PV Bill of Material Market Report offers continuous tracking and analysis. The report is designed to help enterprises reassess their positioning and refine strategies amid the evolving trade environment.

The report contains:

• Overview of global BoM markets and competitive landscape

• Supply-demand data and price trends for glass, encapsulants, frames, ribbons, junction boxes, silver paste, backsheets, and other materials

• Policy analysis and summary of trade barriers

Contact us for a sample of the "PV Bill of Material Market Report" to explore the upcoming challenges and opportunities.