Compliance achieved: Trina module imports meet UFLPA, AD/CVD requirements

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The US Department of Commerce’s (DOC) final determination on Anti-Dumping and Anti-Circumvention (AD/CVD) duties and the US Customs and Border Protection’s (CBP) Uyghur Forced Labor Protection Act (UFLPA) have stirred uncertainty in the solar industry.

Trina Solar says the company has taken steps over the past several years to prevent forced labor in its supply chain and to ensure that modules imported into the US comply with the country’s regulations.

AD/CVD tariffs and compliance

The DOC’s 2012 ruling exempted modules produced outside China, provided they incorporated cells made outside of China. However, the recent DOC ruling extended AD/CVD rates to modules from other Southeast Asian countries. Although this change conflicts with the previous definition of “substantive transformation,” Trina Solar says it has already diversified its supply chain to mitigate these challenges.

According to the company, it expanded its operations to comply with regulations before the DOC’s recent determination. The company opened a 6.5 GW wafer facility in Vietnam and has used non-Chinese polysilicon for all modules imported into the US market since 2021. By using polysilicon sourced from the United States and Europe and by manufacturing wafers, cells, and modules in Southeast Asia, Trina Solar has established a fully independent supply chain outside China to meet US market requirements.

In 2022, Trina Solar expanded its compliance infrastructure to trace materials upstream to mining activities. This expansion reflects the company’s dedication to preventing the use of materials associated with forced labor allegations.

The manufacturer has also secured the capability to procure 4-of-6 Bill of Materials (BOM) listed by the DOC for its modules outside of China, which further ensures compliance with US regulations.

UFLPA compliance

Trina Solar emphasizes it has been sourcing 100% of the polysilicon used in its US modules from well-respected United States and European partners since 2021. It took this step as a proactive measure to ensure ethical sourcing practices and to prevent the inclusion of conflict minerals, aligning with the UFLPA.

Rapid Response System

Trina Solar established an advanced traceability infrastructure and rapid response system that enables efficient response to CBP compliance requests, providing detailed documentation.

In a time of regulatory uncertainty, Trina Solar offers a model for ethical and compliant supply chain practices in the solar industry. Its proactive approach and commitment to sustainability demonstrates that it is possible to navigate the challenging regulatory landscape while upholding the highest ethical standards.

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