2026 is shaping up to be another tariff and supply chain rollercoaster, from the anticipated determination dates for AD/CVD cases to the vast array of potential outcomes for Section 232 investigations into polysilicon and uncertainty around any future action on processed critical minerals. What should be top of mind as you plan your solar and energy storage development, procurement, and risk mitigation strategies? What options are available today that can help your company stay ahead of the competition, and what actions should you take now?
Here’s a look at the risks you should have on your radar as we start the year, along with our recommendations to best plan your product strategy and procurement.
Click here to jump directly to Anza’s recommendations
AD/CVD (Antidumping and Countervailing Duties) Cases
Active Anode Material
Initiated last year, this AD/CVD case targets imports of active anode materials from China and requires all battery cells, modules, or raw materials to comply with established tariff values. Although preliminary determinations were lower than expected, they remain significant, with an estimated impact of $8–$15/kWh at the block level. Following delays from the government shutdown, the final ITC determination is now expected in January 2026, with final injury determinations due in March.
Additionally, while imported ESS blocks were initially excluded from the tariff scope, the petitioners have since requested their inclusion. The DOC may rule them to be within scope when issuing the final determination
India/Indonesia/Laos (“Solar IV”)
The latest in a series of solar AD/CVD cases focuses on crystalline silicon photovoltaic cells, whether imported individually or as modules, produced in India, Indonesia, and Laos. This case aims to impose additional duties on these imports, though the specific rates are currently to be determined. Due to deadline extensions resulting from the recent government shutdown, preliminary CVD determinations are now expected by February 23, 2026. The risk of price increases is real following the announcement of the preliminary CVD determination, as cell/module supply from these countries may become uneconomical for the US market. Some large, sophisticated players with high commitment to the US market have already begun adjusting their supply chains, anticipating these tariffs.
Preliminary AD determinations are due on March 27, 2026. Of note, mandatory respondents from India recently withdrew from the AD investigation, which will likely result in high AD rates for India (expected to exceed 200%) due to adverse facts available. Because this cause focuses on cells, whether or not they are imported as modules, the high AD rate would apply to modules with Indian cells. Most of the major Indian module exporters are not using cells from India and therefore would not be impacted by this extremely high rate.
Section 232 Investigations
Multiple Section 232 investigations, led by the Bureau of Industry and Security (BIS), are evaluating the impact of specific imports on U.S. national security. By law, BIS must submit its findings and recommendations to the President within 270 days of initiating an investigation. The President then has 90 days to concur with the report and implement any policy remedies.
Critical Minerals and Derivative Products
On April 22, 2025, an investigation was initiated under Section 232 to evaluate critical mineral components essential for energy storage devices. After delays due to the government shutdown, a presidential proclamation was issued on January 14, 2026, choosing not to impose tariffs on critical minerals and derivative products for now. Instead of tariff remedies, the President directed his administration to pursue supplies from trading partners, consider price floors, and continue to monitor the need for further action, including tariffs, down the road.
Polysilicon
On the PV side, a Section 232 investigation into imported polysilicon and its derivatives was launched on July 1, 2025. This probe could affect all imported polysilicon, and it is currently unknown if certain country-specific exclusions may be carved out as the investigation progresses. It also remains unclear whether the resulting tariffs will apply strictly to raw polysilicon or to the finished product as a whole. With limited U.S. wafer capacity available, you are likely to have to at least import the wafer, which would carry a $0.07/watt tariff if the administration were to follow the recommendation from the Coalition for a Prosperous America. It is possible that the tariffs would be higher if you were to import cells or modules.
The statutory deadline for the final report is March 28, 2026, with the President needing to concur with findings within 90 days (on or about June 26, 2026). While experts initially anticipated an accelerated timeline, delays due to the government shutdown and ongoing U.S.-China trade discussions may be slowing down the process. Currently, the administration may not be inclined to take aggressive China-specific action until after the planned April summit with China. However, this report could still be issued at any time, and there is a material chance it could come out any time over the next several weeks as the administration originally indicated intent to expedite proceedings. An early decision is especially likely if the Supreme Court determines IEEPA tariffs to be illegal, prompting accelerated Section 232 remedies as another countermeasure to address national security concerns.
China VAT Export Rebates Cancellation
China’s Ministry of Finance announced on January 9, 2026, that it is phasing out Value-Added Tax (VAT) export rebates for storage and solar product exports starting April 1, 2026. For battery products, the current 9% rebate will be reduced to 6% (from April 1 to December 31, 2026) and fully cancelled starting January 1, 2027. The PV export VAT rebate will drop from 9% to 0% beginning April 1, 2026.
Effectively, this transition makes Chinese BESS products roughly 3% more expensive starting in April, with an additional 6% cost increase arriving in 2027. It is unknown if exporters or OEMs will absorb these costs or pass them on to buyers. With roughly three months before VAT rebates are reduced, we expect a surge in outbound shipments from China, with some buyers accelerating purchase timelines.
Potential 25% Tariff on countries doing business with Iran
No presidential documentation or official details have been issued regarding this new potential tariff, which President Trump threatened on Truth Social on January 12, 2026. It is likely that this new tariff would be issued under IEEPA and could take effect very quickly, similar to the previous IEEPA tariff rollout in spring 2025. If the Supreme Court invalidates the Trump Administration’s broad use of IEEPA to justify tariffs, the Administration may be left scrambling for other authority to issue these tariffs, if they are issued at all. President Trump seems to have gone silent on these tariffs for now, which some have interpreted as backing away from these threatened tariffs; however, this could change at any time.
There are many open questions regarding this tariff, including timing, effective date, scope, whether it would be cumulative with other tariffs, and whether there would be any exceptions. If implemented, it would affect countries such as China, India, Turkey, and Russia. This potential tariff carries some risk for buyers considering purchases from these countries (primarily Turkey and India for US module buyers).
Potential 10% Tariff on 8 European Countries
On January 17, 2026, President Trump threatened a new 10% tariff on eight European countries, “until such time as a Deal is reached for the Complete and Total purchase of Greenland,” in another Truth Social post. This tariff would target goods from Denmark, Norway, Sweden, France, Germany, the United Kingdom, the Netherlands, and Finland, starting February 1, with the rate climbing to 25% on June 1. With Germany home to one of the largest inverter manufacturers, both BESS and PV supply chains could be affected by this tariff.
Similar to the potential tariff on countries doing business with Iran, no presidential documentation or official details have been issued regarding this new potential tariff, and it is unclear whether they would be cumulative. As of January 21, 2026, President Trump stated that he will not impose the tariffs set to take effect on February 1, 2026.
Foreign Entity of Concern (FEOC) Requirements & Guidance
As of January 1, 2026, FEOC requirements are officially in effect. To maintain eligibility for tax credits, clean energy projects must ensure that any materials sourced from a Prohibited Foreign Entity (PFE) remain below specific percentage thresholds, which increase annually and vary by technology. For projects beginning construction in 2026, at least 40% of manufactured products for solar and 55% for energy storage must be sourced from non-PFE entities.
The industry is awaiting critical guidance from the Treasury on the Material Assistance Cost Ratio (MACR) and additional clarification on the definition of “effective control,” which is expected to be released in January 2026. Current thinking is that this will be high-level staff guidance (similar to the first set of guidance on the Domestic Content Bonus Credit), which would then go to proposed rule later this spring. It is not clear how long taxpayers may continue to rely on the existing guidance before they must adopt the new guidance exclusively. Treasury will likely clarify the effective date of new rules in future sets of guidance.
What should my strategy be now?
While timelines may shift and new risks may arise, getting access to up-to-date pricing, supply chain, product, and transaction data from across the market will be essential to finding the lowest-risk, highest-value option for your projects.
Anza’s one-of-a-kind data and analytics intelligence hub and expert support are available to not only help you with mitigating the risks outlined above, but also to gain a competitive advantage among your peers. Our platform provides a live, continuously expanding database of manufacturers and products, with thousands of price updates each quarter. Anza captures the latest industry shifts, including new tariffs, trade duties, and FEOC compliance updates. By layering your company’s specific technical requirements, risk thresholds, and project economics onto this data, you can instantly compare products and generate data-driven supplier shortlists or RFPs tailored to your strategy.
Our expert team also provides services to support your projects throughout their lifecycle, including procurement support for solar modules, BESS, and transformers. With over 8 GW of solar and 8.6 GW of storage projects supported by our team, our sizable market footprint allows us to move fast when the clock is ticking on tight market deadlines and secure the most competitive deals.
Depending on your project strategy, type, and timeline, our experts’ current recommendations include high-level strategies outlined below:
Solar Projects
Given the rapidly shifting trade landscape, we strongly advise clients to lock in solar procurement deals for 2026 & 2027 deliveries now, ideally under terms that are not subject to price adjustments once the Section 232 polysilicon tariffs take effect. Proactive procurement is essential, as waiting to secure equipment until after these determinations are finalized is expected to be significantly more costly.
Anza worked with key supplier partners to develop creative, fixed-price contracting options with sourcing flexibility, allowing clients to secure product and favorable pricing. Our historical and current analysis of our platform data shows that contracting now with a fixed-price agreement delivers a better outcome than waiting until the tariff is public and there is a rush on the market. We’ve recently seen pricing from suppliers below 30 cents per watt using this contract setup, with a refundable deposit of less than 5%, and with strong protections against tariff risk.
To help navigate ITC FEOC complexities, we are providing our clients with deep visibility into the FEOC readiness and maturity of various module sellers and assemblers. Our supplier classification system, going live on our platform in Q1 2026, provides our clients with different levels of verification and due diligence resources, ranging from internal supplier compliance documentation and certifications to rigorous independent audits conducted by Anza or other credible firms.
Energy Storage Projects
For BESS projects, sourcing strategies differ significantly based on whether a project was safe-harbored in 2025 and whether there is intent to utilize tax credits. Furthermore, depending on the delivery timeline, projects face potential upside price risk due to increasing commodity costs.
Projects that successfully safe harbored in 2025 are in an advantageous position, as they are not subject to the new FEOC Material Assistance Cost Ratio. For relevant projects with 2026 and 2027 CODs, inventory options remain available from a diverse pool of suppliers. While new supply from China is an option, it comes at a higher Section 301 tariffs and carries incremental risk due to significant tariff exposure, including Section 232 duties and the Active Anode Material AD/CVD case.
Alternatively, new supply from Southeast Asia (SEA) and the Middle East/Africa (MEA) will begin scaling up in the second half of 2026. While these regions offer lower tariff exposure, developers and buyers should account for potential delays and quality-control risks common to the activation of new manufacturing lines. For those prioritizing long-term stability, domestic options are available from select vendors, with a strategic build-out of U.S. manufacturing expected to add substantial capacity through 2028.
For projects that did not safe harbor in 2025, the path to qualifying for the Investment Tax Credit (ITC) now requires FEOC-compliant supply. Compliance options are currently centered on domestic manufacturers (following the expansion timelines noted above), with a limited but growing number of eligible sources emerging from the MEA and SEA regions. If a project cannot meet these sourcing requirements, developers may choose to forgo the ITC and utilize FEOC non-compliant supply. However, this route remains fully exposed to the current aggressive tariff landscape, which may significantly impact overall project economics.
Anza’s team is uniquely qualified to help you weigh factors, including lifecycle costs, commercial, technical, and supplier data, to mitigate risk and execute an SPA. Our in-depth knowledge of supplier track records, commercial standing, and historical transaction pricing enables us to deliver competitive, well-informed product selections to support your final decision.
Transformer Procurement
If you’re racing to Safe Harbor with transformers before the solar July 4, 2026, commence construction deadline, now is the time to act, as inventory is shrinking.
Transformer procurement is a significant bottleneck, with MV lead times up to a year and HV lead times stretching 2-4 years. Our new Transformer Procurement Service helps support safe harbor qualification ahead of the deadline, addressing market opacity and long lead times. Putting together a list of suppliers to participate in an RFP can often take buyers 3+ weeks, but it can now be completed in 30 minutes with Anza.
In a market defined by shifting timelines and evolving trade risks, success requires a proactive strategy rooted in real-time data and expert insights and the ability to move fast. For many projects, acting now can help you lock in the lowest-risk, highest-value option. Connect with our team to discover how our unique platform and advisory services can help you secure optimal pricing and terms while proactively mitigating complex market and regulatory risks.
