What the New Solar Import Duties Do to a Pond Array Budget

Two things happened to the module line of your bill of materials in the last two weeks, and neither of them had anything to do with water. On November 5 the International Trade Commission's injury finding was published, switching duty cash deposits back on for crystalline silicon cells from India, Indonesia and Laos. On November 9 Commerce published the duty orders themselves. A separate minimum import price of $0.38 per watt on modules takes effect December 4.

If you are quoting a floating array for a retention pond, an irrigation reservoir or a process lagoon, the float package and the labor did not change. The modules did. Here is what the orders actually say, what the numbers do to a 20 kW pond budget, and what to pin down with your supplier this month.

What changed, precisely

The Commission filed affirmative determinations on November 2, 2026, finding the U.S. cell and module industry materially injured by imports from the three countries; the notice was published November 5, 2026 at 91 FR 69865 (ITC determinations notice). Commerce then published the antidumping duty orders at 91 FR 70862 and the countervailing duty orders at 91 FR 70843, both on November 9, 2026 (AD orders, CVD orders).

The rates, as published:

Two details matter more than the headline percentages. First, the cash deposit rates differ from the dumping margins because they are adjusted for export subsidy offsets, so the number your customs broker quotes is not always the number in the press release. Second, the India margins were calculated on facts available with adverse inferences, which is what happens when respondents do not supply usable data — not a finding about any particular panel's quality.

The scope covers crystalline silicon photovoltaic cells at least 20 micrometers thick with a p/n junction, whether or not assembled into modules, including modules, laminates and panels. Thin-film products made from amorphous silicon, cadmium telluride or copper indium gallium selenide are excluded, as are products already covered by the earlier China and Southeast Asia orders (AD orders). The written scope controls, not the tariff headings — a point worth repeating to anyone who tells you their product "isn't on the list."

There is also a gap in the timeline that a sharp-eyed buyer will notice on an invoice. Provisional measures expired October 24, 2026, and entries from October 25 until the day before the ITC notice published are liquidated without regard to antidumping duties (AD orders). Cargo that cleared in that window carries a different duty position than cargo that cleared on November 5. If a supplier is offering you inventory at an unusually good number, this is probably why, and it is finite.

Three layers, and the one that will actually bind

Module duty exposure in late 2026 comes in layers:

1. Country-specific AD/CVD orders. The ones above, plus the existing orders on China and the Southeast Asian countries covered earlier.
2. Section 232 minimum import prices, effective 12:01 a.m. Eastern on December 4, 2026: $21/kg for polysilicon, $100/kg for ingots and wafers, $0.22/W for cells and $0.38/W for modules, plus a 15% ad valorem tariff on derivative products (EY).
3. Stacking. Anza reports the 15% applies on top of existing duties, including AD/CVD orders, for origins other than the treaty partners and the UK (Anza).

For practical purposes the three countries now under order are priced out rather than merely taxed — combined rates in the low hundreds of percent do not survive a competitive bid. So the layer that will set your module price is the December 4 floor, not the new orders. Anza's data makes the size of that move concrete: among suppliers that repriced, median imported module pricing moved from about 27 cents per watt before the August 7 proclamation to about 38 cents per watt for delivery after December 4, with roughly 24 to 25 cents per watt available on select modules that can clear customs before the deadline (Anza).

What an 11-cent module move does to a pond array

Floating solar budgets split differently than ground mount, so it is worth seeing the module swing against the structure line rather than against a total installed cost.

Take the 20 kW three-phase configuration: 32 modules at 640 W is 20,480 W of nameplate, and the structure kit is $4,796, which works out to about $0.234 per watt for floats, rails, mounting hardware, inverter mounts and grounding (kit pricing). Panels, inverters and wiring are separate line items.

The module delta on a single 20 kW array is roughly half the entire structure-kit line. Scale that to a 250 kW municipal pond project and the same 11 cents per watt is about $27,500 of budget that did not exist in your spring pricing. That is not a reason to abandon a project; it is a reason to re-run the arithmetic rather than reuse a stale number. Our ROI calculator takes a module price as an input for exactly this reason, and the components overview spells out which parts of the system are in the kit and which you are buying separately.

One scope note, stated carefully: these orders cover cells and modules. Racking, flotation and balance-of-system hardware are separate lines with their own tariff classification and their own duty treatment, which varies by product and origin. Ask any supplier — ours included — to confirm the landed-cost basis of their quote in writing rather than inferring it.

What to settle with your supplier this month

1. Get module origin and the expected entry date in writing. Origin determines which orders apply; entry date determines whether the December 4 floor applies.
2. Ask who absorbs a rate change. A quote that is silent on duties is a quote that leaves the risk with you. Push for DDP with duties paid, or an explicit allocation.
3. Confirm whether pre-deadline cargo is real. "Clearing before December 4" is a customs event, not a ship date. Ask for the sailing schedule and the broker's filing plan, and ask what happens if it slips.
4. Price the project twice. One number at today's quote, one at $0.38/W modules. If the project only works at the lower number, you have a timing problem, not a pricing problem.
5. Keep the credit test separate from the tariff question. For facilities beginning construction after December 31, 2025, the 48E material assistance cost ratio is 40% in 2026, rising to 45% in 2027, and taxpayers may generally rely on a supplier certification absent reason to know it is wrong (McGuireWoods). Our FEOC page covers how that test is structured. Cheap modules that fail the ratio are not cheap.

The tax clock is still the harder deadline

Tariffs change the price of a project. The credit deadline changes whether there is a project. Under current law the 48E credit does not apply to solar placed in service after December 31, 2027 unless construction began on or before July 4, 2026; projects that started before that date get the four-year continuity window instead (Olson Partners). The beginning-of-construction rules themselves are unsettled: IRS Notice 2025-42 was vacated in June 2026, restoring the 5% cost safe harbor for larger solar, with an appeal expected (McGuireWoods).

If a module order slips six weeks and pushes a placed-in-service date past a credit deadline, the tariff saving is irrelevant. Sequence procurement around the tax date first and the tariff date second.

Bottom line

The new orders are real and well documented, but for most pond projects they remove three sourcing countries rather than raise your price directly. The December 4 minimum import price is the number that will show up in your quote — roughly an 11-cent-per-watt move on imported modules, which on a 20 kW array is about half the cost of the entire floating structure. Get origin and entry dates in writing, price every open proposal at both module numbers, and do not let a tariff negotiation push a project past a tax deadline that does not move. If you are an installer or EPC trying to hold a pond project together through this, our dealer program exists to keep the structure side of the quote predictable while the module side is not. We covered the mechanics of the December 4 floor in more detail in an earlier post on the module price floor.

This is general information, not tax or legal advice. Duty rates, scope rulings and tax guidance change, and application depends on your specific facts. Consult your customs broker and tax advisor before relying on any of it.

Sources: ITC determinations notice, 91 FR 69865 · Antidumping duty orders, 91 FR 70862 · Countervailing duty orders, 91 FR 70843 · EY: Section 232 minimum import prices · Anza: module prices after Section 232 · Anza: how the price floor works · McGuireWoods: FEOC guidance · McGuireWoods: Notice 2025-42 vacated · Olson Partners: 48E timeline