Revenue Impact of Retroactive Duties on U.S. Solar Imports under the 2022-2024 Tariff Moratorium

Revenue Impact of Retroactive Duties on U.S. Solar Imports under the 2022-2024 Tariff Moratorium

In June 2022, the Biden administration introduced a two-year tariff moratorium, temporarily suspending import duties on solar cells and panels from four key Southeast Asian exporting nations—Cambodia, Malaysia, Thailand, and Vietnam. This moratorium, lasting until June 6, 2024, was primarily designed to prevent short-term disruptions to the U.S. solar industry, accelerate deployment of renewable energy infrastructure, and allow domestic solar manufacturing capabilities time to scale up. However, this policy has led to a massive influx of imported solar products from countries and companies with deep links to China, creating an unprecedented stockpile that now faces potential retroactive duties.

Revenue Estimate Summary

Estimated Retroactive Duties on Imports Not Used before the Dec 2024 Deployment Deadline:

  • $22 to $25 billion in tariff revenue (35-40 GW of solar imports)

Estimated Retroactive Duties on Imports during the Entire Moratorium Period:

  • $53.9 to 67.4 billion in tariff revenue (70.9 GW)

Retroactive Duties on Unused Solar Imports

By the moratorium’s December 2024 installation deadline, substantial volumes of imported solar components remained unused and stored in U.S. warehouses. Industry estimates indicate approximately 35–40 total GW of solar imports that were stockpiled and not used by the December 2024 deployment deadline. Based on historical import trends, we estimate this is broken down into 6–6.5 GW of solar cells and 29–33 GW of solar panels. Using average declared import values of $0.14 per watt for solar cells and $0.27 per watt for solar panels, this translates to approximately $8.7–10 billion worth of unused imported solar inventory.

If retroactive duties are pursued based on prevailing tariff rates—15.25% countervailing duties (CVD) and 238.95% antidumping duties (ADD)—the retroactive tariff revenue from these stockpiles would be substantial. Specifically, these stockpiled imports alone would yield retroactive duties totaling approximately $22–25 billion. Such an immense revenue gain would be welcome amid ongoing budget negotiations and would have the added benefit of correcting some of the financial gains Chinese and other foreign solar producers acquired during the moratorium. This would give a significant boost for domestic solar manufacturers and increase confidence and domestic investment in the sector.

Broader Impact: Retroactive Duties on All Solar Imports

Extending retroactive duties to cover the entirety of the imports brought in during the moratorium period further magnifies the potential economic impact. From June 2022 through the end of May 2024, U.S. importers brought in roughly 88.2 GW of solar cells and panels from Cambodia, Malaysia, Thailand, and Vietnam, with a total declared import value of approximately $26.5 billion. Applying retroactive tariffs to this entire moratorium period would increase the financial benefits dramatically, resulting in upwards of $67.4 billion in total retroactive duties. A conservative estimate accounting for exemptions or other loopholes would still yield about $53.9 billion in retroactive duties (about 80% of imports during this period). 

This more than doubles the tariff revenue compared to the unused stockpile scenario, illustrating the massive scale of the disruption these solar imports have caused during the moratorium period.

Conclusion

Implementing retroactive duties on imported solar products from the Southeast Asian nations affected by the 2022–2024 tariff moratorium presents a crucial opportunity to strengthen the U.S. solar industry significantly. These tariffs would not only recapture substantial revenue—potentially ranging from $22 billion to as much as $67.4 billion—but would also level the playing field for American solar producers who have struggled against subsidized and artificially low-priced imports linked directly to China.

By imposing these duties, the U.S. government would decisively address the unfair advantage foreign manufacturers gained during the moratorium period, revitalizing domestic solar manufacturing. The resulting infusion of funds and the removal of unfairly priced inventory from the market would dramatically improve the competitive landscape, spurring increased investment in U.S.-based solar manufacturing facilities and supply chains. This, in turn, would enhance domestic solar market share, ensuring that growth in renewable energy directly benefits American companies and workers.

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