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Author | Alan Tu |
Updated | December 09, 2024 |
U.S. Department of Commerce issued preliminary findings in the antidumping duty investigations of cells from Cambodia, Malaysia, Thailand, and Vietnam
On November 29, the U.S. Department of Commerce (DOC) issued a preliminary ruling on the anti-dumping (AD) investigation of crystalline cells from Cambodia, Malaysia, Thailand, and Vietnam, announcing the dumping rates for each exporter/producer. This ruling greatly affects Southeast Asian PV exports to the U.S. and could reshape the global supply chain.
The AD duties for all countries, except Malaysia, are consistent with those outlined in the April petition. The preliminary ruling mostly aligns with the petitioners’ request.
The AD duty table below shows several key trends:
1. The “all others” rates for each country, from lowest to highest, are Malaysia, Thailand, Cambodia, and Vietnam, mostly between 50-60%, matching InfoLink's expectations without adverse inferences.
2. Some companies are marked as "This rate is based on facts available with adverse inferences" (see the red sections of the table below). This indicates that these companies either lacked transparency or refused to provide data, so investigators assumed the worst and applied higher tax rates. Cambodia, Malaysia, and Thailand have companies in this category. Vietnam's overall tax rate is also marked with this note, likely due to its socialist system and partially free economy, resulting in the highest rate in this investigation.
3. Hanwha Q Cells is marked as "This rate is de minimis" (see the blue section of the table below). A similar situation occurred with Thailand's Trina Solar and Vietnam's Boviet in previous CVD rulings. This indicates that the authorities considered their dumping or subsidy margins negligible, with limited market impact, resulting in a lower tax rate.
4. Some Thai companies, like Trina Solar, Sunshine Electrical Energy, and Taihua New Energy, are marked as "N/A" with no tax rate published, indicating "Not Applicable" or "Not Available." Missing data could be the reason, and the tax rates may be provided later.
5. Cambodian manufacturers such as Hounen Solar and Solar Long likely received high tax rates for not cooperating. This matches a Reuters report from October 21 which stated that these companies could not continue allocating resources to participate in this investigation.
Anti-dumping tariff rates for manufacturers in Cambodia, Malaysia, Thailand, and Vietnam
InfoLink Analysis
The chart below shows the combined AD/CVD rates for major exporters to the U.S. Hanwha Q Cells has the lowest rate among the four countries, with a 0.00% AD rate, making it the top choice for exports to the U.S. in the preliminary ruling.
Combined AD/CVD rates vary across regions. Malaysian companies generally face rates around 30%, while some Vietnamese companies fall between 50-60%. Non-listed Thai companies are subject to the “all others” rates, which are around 80%. Rates in Cambodia range from 120-130%. LONGi's Vietnamese subsidiary, though not listed for anti-dumping, may face a rate as high as 271.28% under the “all others” rates.
This analysis assumes that Southeast Asian export prices remain at USD 0.12/W for TOPCon cells and USD 0.25/W for TOPCon modules. For Southeast Asian integrated module companies, the 14.25% Section 201 tariff combined with over 30% AD/CVD rates would lead to negative margins. For cell manufacturers within the 12.5 GW Section 201 tariff-free quota using non-Xinjiang wafers, margins would turn negative at AD/CVD rates of 50% or higher. The AD/CVD ruling still leaves export opportunities open for Malaysian companies but excludes any possibility of strategies like raising prices or cutting costs. The ruling is only preliminary, with a final decision expected on April 18, 2025, which may include retroactive measures. Exporting under current low rates could risk future retroactive rate adjustments.
Analysis for cells and modules in the U.S. based on supply demand dynamics:
US domestic cell capacity growth remains relatively slow in the short term, with clear demand for cell procurement over the next three years. The primary sourcing strategy will focus on cell supplies from Indonesia and Laos. However, capacities in these regions are insufficient to meet US demand, leaving a supply gap that must be filled by other regions. Thus, countries like Malaysia and Taiwan will likely supply the US market in the short term. Nonetheless, given the tightened US policies, supply volumes from these regions will gradually diminish.
US domestic module capacity can generally meet demand. However, considering effective capacity and actual utilization rates, there remains a short-term need for supplemental imports to fill market gaps. Regions such as Indonesia, Laos, India, and even Malaysia are still likely to supply modules to the US market.
Overall, the most optimal route for manufacturers exporting to the U.S. remains utilizing products from regions other than Cambodia, Thailand, Vietnam, and Malaysia, such as Indonesia and Laos, which are less risky and more cost-effective. Many companies have relocated their module production lines from these four Southeast Asian countries to Indonesia, while cell production lines are increasingly being set up directly in Indonesia and Laos, forming PV manufacturing hubs. However, it remains crucial to monitor potential US policy adjustments that may impact these regions.
InfoLink has released the US Market Report: PV Supply Chain Analysis and Market Prospect, providing insights into the impact of the recent preliminary AD/CVD rulings on the PV industry and revealing rapid changes in the US market. The report covers policy interpretations, tax rate impact assessments, export-to-the-U.S. scenarios, and strategic recommendations.
InfoLink provides a comprehensive analysis of the US market landscape, offering precise cost assessments tailored to exporters to the U.S. and US developers, helping players respond to market shifts and develop efficient strategies. For more details and data services, please feel free to contact us.