Canada quietly ends eleven years of anti-dumping and countervailing duties on Chinese photovoltaic modules after domestic producers decline to defend the order, reshaping cost assumptions for solar developers on both sides of the border
OTTAWA, September 23, 2026 – Canada has ended more than a decade of trade protection for its domestic solar manufacturing sector, after the Canadian International Trade Tribunal terminated an expiry review of anti-dumping and countervailing duties on photovoltaic modules and laminates from China and rescinded the underlying order outright.
The Canada Border Services Agency published its notice of expiry of order on September 22, confirming to importers and customs brokers that duties will no longer be collected on the affected goods. The Tribunal’s own announcement, issued from Ottawa on September 17, stated that it had terminated the expiry review of an order originally made on March 25, 2021 in expiry review RR-2020-001, and had accordingly rescinded that order.
What makes the decision unusual is not the outcome but the mechanism. The Tribunal did not find that Chinese exporters had stopped dumping, nor that subsidization had ceased, nor that the Canadian industry would be safe from injury if the measures came off. It terminated the review because the domestic industry that the measures were designed to protect did not show up to defend them.
Under Canada’s Special Import Measures Act, the Tribunal may terminate an expiry review at any stage if it concludes that the review lacks support from domestic producers. That conclusion is typically inferred when producers fail to file notices of participation or fail to participate in any substantive way. Where the Tribunal reaches that conclusion, it issues an order rescinding the measure. Trade publication pv magazine, reporting the decision on September 21, described the action as best understood as a procedural termination for lack of domestic industry support rather than a substantive finding on injury.
The practical consequence is immediate and unambiguous. Chinese crystalline silicon modules and laminates, together with thin film products made from amorphous silicon, cadmium telluride and copper indium gallium selenide, can now enter Canada without the anti-dumping and countervailing duties that have applied since the original finding in 2015 and the continuation order of 2021.
What the order covered
The rescinded order had a wide product scope. It captured photovoltaic modules and laminates originating in or exported from the People’s Republic of China, consisting of crystalline silicon photovoltaic cells, and it also reached thin film products built on amorphous silicon, cadmium telluride and copper indium gallium selenide chemistries.
Two carve-outs existed from the beginning. Modules and laminates with a power output not exceeding 100 watts were excluded, which kept small consumer and recreational products outside the duty net. So were modules and laminates incorporated into electrical goods where the function of the finished good is something other than generating electricity, a provision designed to prevent the order from sweeping in garden lights, calculators, signage and similar consumer items with incidental photovoltaic components.
A third exclusion was added more recently. In a separate interim review, designated RD-2025-001, the Tribunal considered a request filed in August 2025 by Kings Solar Solutions to exclude flexible solar panels engineered to be affixed to curved surfaces, including vehicle fairings. That proceeding concluded on March 13, 2026 with an amendment excluding flexible photovoltaic modules rated at up to 200 watts and affixed to curved vehicle surfaces.
That interim review and the expiry review now terminated were separate proceedings addressing separate questions, and pv magazine noted that the March exclusion neither signalled nor produced the broader termination. They simply ran on parallel tracks and reached their conclusions independently, the narrow one first and the sweeping one six months later.
An order nobody came to defend
Expiry reviews are the routine housekeeping of trade remedy law. Canadian anti-dumping and countervailing measures lapse automatically after five years unless the Tribunal, following an inquiry, determines that removing them would likely result in resumed or continued dumping or subsidizing and that such dumping or subsidizing would likely cause injury to the domestic industry.
The process depends on domestic producers participating. They must file notices of participation, respond to questionnaires, supply confidential pricing and volume data, and typically retain counsel to make the case. The Tribunal cannot construct an injury record on its own initiative. Where the industry sits out, the statutory logic is that there is no industry seeking protection, and the measure comes off.
The September 17 press release confirms the outcome but does not set out the Tribunal’s reasoning. Full reasons are normally published separately and were not available at the time the decision was reported.
Publicly available material does not establish whether Canadian producers such as Heliene or Silfab Solar sought continuation of the order in this proceeding. No public reaction from the Canadian Renewable Energy Association, from the Canadian Solar Industries Association or from individual domestic producers had been confirmed at the time pv magazine went to press on September 21, and none had surfaced by the time the CBSA notice circulated to the customs brokerage community on September 22.
That silence is itself information of a kind. Trade remedy proceedings are expensive. Participation requires legal fees, internal data collection, and executive time. A domestic producer weighs that cost against the protection the order actually delivers. Where a manufacturer has reoriented toward export markets, toward product segments the order never covered, or toward supply arrangements that make Chinese modules an input rather than a competing product, the calculation can tip against spending money to defend a measure of declining relevance.
Canadian module assembly has undergone exactly that kind of reorientation over the past several years. Firms with Canadian manufacturing footprints have increasingly built their commercial strategy around access to the far larger United States market and around policy incentives available there, which changes what a Canadian anti-dumping order is worth to them.
The China context
The termination lands in the middle of a deliberate and ongoing warming of Canada’s commercial relationship with China, though the Tribunal itself has not drawn any connection between the two.
In January 2026, Ottawa announced a preliminary joint arrangement with Beijing addressing bilateral economic and trade issues. Under that arrangement, Canada agreed to permit up to 49,000 Chinese made electric vehicles annually at the standard most favoured nation tariff rate of 6.1 per cent, replacing the 100 per cent surtax that had been imposed in 2024 under the previous government. The quota is set to rise on a schedule reaching 70,000 vehicles by 2030.
The same arrangement addressed canola. Canada indicated it expected China to reduce tariffs on Canadian canola seed to a combined rate of roughly 15 per cent by March 1, 2026, and expected that canola meal, peas, lobster and crab would be exempted from anti-discrimination tariffs from that date through the end of the year.
Ottawa also signalled at the time that it would not proceed with previously contemplated tariffs on certain Chinese solar products and semiconductors, measures that had been floated in 2024 alongside the electric vehicle surtax but never implemented.
Canada additionally extended to the end of 2026 its remission measures for certain Chinese steel and aluminium products in short supply domestically, covering 66 product specific tariff lines comprising 11 full remissions and 55 partial remissions, along with 49 company specific tariff lines, and expanded coverage to seven additional steel products, two aluminium products and four steel derivative products.
Against that backdrop, the disappearance of a longstanding trade remedy on Chinese solar modules fits a visible pattern. But the Tribunal operates under a statutory framework that is formally insulated from foreign policy. It applies the Special Import Measures Act to the record in front of it. On the record in front of it, no domestic producer made the case for continuation, and the statute directs a particular result when that happens. The connection between the diplomatic thaw and the trade remedy outcome has not been confirmed by the Tribunal, and on the available evidence the two developments are better understood as coincident than causal.
A divergence with Washington
The Canadian decision runs directly counter to the direction of United States policy, and the contrast is now stark.
The United States continues to apply anti-dumping, countervailing and Section 301 measures to Chinese solar products, and has spent 2026 extending those protections further upstream. Measures introduced during the year reach beyond finished modules to cells, wafers, ingots and polysilicon, an effort to close circumvention routes and to build a domestic supply chain that does not depend on Chinese intermediate goods.
Canada has now moved the other way, removing the module level protection it had while never having built the upstream measures that Washington is layering on.
For North American trade policy this creates a genuine asymmetry. Two neighbouring markets, tightly integrated in most respects, now treat the same imported product under fundamentally different rules. Chinese modules entering Canada face no trade remedy duty. The same modules entering the United States face a stack of them.
That asymmetry raises transshipment and origin questions that Canadian importers and exporters will need to think about carefully. A Chinese module imported into Canada duty free does not become a Canadian good. United States trade remedy law looks to the country of origin, not the country of last shipment, and Canadian firms that buy Chinese modules for resale or integration into equipment bound for the United States should not assume that routing through Canada changes the duty exposure on the other side of the border.
What it means for Canadian solar developers
For utility scale and commercial solar developers operating in Canada, the immediate effect is downward pressure on module procurement costs.
Modules typically represent a substantial share of the capital cost of a photovoltaic installation. Removing an anti-dumping and countervailing duty stack from one of the world’s largest supply sources widens the field of eligible suppliers and creates competitive pressure on prices from all sources, not only Chinese ones. Suppliers from other origins that had been competing against duty inflated Chinese pricing will find their position changed.
Developers with projects in procurement should be reviewing their module supply assumptions immediately. Bids priced on the assumption that Chinese product carried duty are now stale. Projects that were marginal on economics may now clear internal hurdle rates. Projects already contracted at higher module prices may find that counterparties seek to renegotiate, or that the developer wants to.
The timing question matters for goods already in transit or already imported. The CBSA notice indicates that duties will no longer be collected on the affected goods. Importers with entries near the effective date, with goods in bonded warehouses, or with provisional duties posted, should be working with their customs brokers to establish exactly which entries fall on which side of the line and whether any refund mechanism is available. Those are file specific questions that turn on entry dates and on the precise terms of the rescission, and they are worth resolving with professional advice rather than assumption.
What it means for Canadian manufacturers
For whatever remains of Canadian module manufacturing, the decision removes a layer of protection against the lowest cost producers in the world.
The scale disparity is not close. Chinese module manufacturing capacity is measured in hundreds of gigawatts annually. Canadian assembly capacity is a rounding error against that figure. The anti-dumping and countervailing duties were never going to make Canadian producers cost competitive with Chinese ones on a pure unit cost basis. What they did was raise the landed price of Chinese product enough to preserve a margin of viability for domestic assembly in parts of the market.
That margin is now gone, at least as a matter of trade remedy law.
Canadian producers retain other advantages. Proximity to Canadian project sites shortens logistics chains and reduces exposure to freight volatility. Domestic content requirements in certain provincial procurement programs and in some federal support mechanisms can favour local product independently of price. Buyers with supply chain traceability obligations, including those responding to forced labour due diligence expectations, may continue to prefer non Chinese sourcing regardless of the duty position.
But those are narrower advantages than a duty wall, and they operate on a subset of the market rather than all of it.
There is also a question of what the absence of participation says about the industry’s own assessment. A domestic producer that believed the order was materially protecting its business would ordinarily defend it. The Tribunal’s finding of insufficient support suggests that the producers who could have participated concluded, individually, that the order was not worth the cost of defending. That may reflect a judgment that their competitive position no longer depends on it.
The broader trade environment
The solar decision arrives at a moment when Canadian trade policy is under extraordinary strain from a different direction entirely.
Canada and the United States are in the middle of the most serious tariff confrontation between the two countries in modern memory. Trade negotiations collapsed in late August after Ottawa concluded that terms proposed by Washington were not in Canada’s interest. The United States imposed 50 per cent tariffs on approximately 27.6 billion dollars of Canadian goods effective August 22 under Section 338 and Section 232 authorities.
Canada responded on September 8 with counter tariffs matching the American measures on a dollar for dollar basis. Canadian surtaxes of 15, 25 and 50 per cent now apply to more than 700 American products, with each product’s rate set to match the American rate on the corresponding Canadian good. The list reaches steel and aluminium and their derivatives, dairy including cheese, household appliances, agricultural equipment, pulp and paper, cosmetics, motorcycles, railway locomotives and electronics.
Prime Minister Mark Carney has defended the measures in blunt terms, telling reporters that the tariffs are necessary to protect Canadian workers, companies and communities, and that Canada cannot allow American goods into the country tariff free while Canadian exporters pay to enter the American market.
Canada’s solar sector has not been insulated from that confrontation. Developers on the Canadian side have reported that American policy shifts are increasingly shaping investment decisions, with the 50 per cent duties introduced in August adding a further layer of uncertainty to project planning. One Alberta based installer, quoted in trade press coverage in late August, described United States policy as a growing factor in Canadian side investment calculations.
So the removal of the Chinese solar duties delivers cost relief to an industry that is simultaneously absorbing significant cost and uncertainty from the south. The two effects run in opposite directions and will not net out evenly across the sector. Developers buying modules benefit. Manufacturers exporting to the United States do not.
Compliance and operational considerations
For importers, customs brokers and trade compliance staff, several practical items follow from the rescission.
Classification and origin determinations remain unchanged. The rescission removes a Special Import Measures Act duty. It does not alter tariff classification obligations, customs valuation rules, origin determination requirements or any other element of the entry process. Goods still need to be classified correctly and valued correctly, and origin still needs to be substantiated.
Internal systems need updating. Brokerage and importer systems that carry Special Import Measures Act flags against the relevant tariff lines and origin combinations should be reviewed so that duty is not assessed in error on post rescission entries. Errors in either direction create reconciliation work and potential penalty exposure.
Contract terms deserve a fresh look. Supply agreements that allocate duty risk between buyer and seller, that contain price adjustment clauses tied to duty changes, or that include most favoured customer provisions may now operate differently than the parties expected when they were signed. Some contracts will contain windfall provisions that direct the benefit of a duty reduction to one party or the other.
Forward looking risk has not disappeared entirely. The rescission removes the existing order. It does not prevent a new complaint. If Canadian producers later conclude that dumped or subsidized Chinese modules are causing injury, they retain the right to file a fresh complaint with the CBSA, which could result in a new investigation and, if the statutory tests are met, new provisional and final duties. That process takes time, and provisional duties do not apply retroactively in the ordinary course, but importers building long term supply strategies should understand that the current position is not permanently fixed.
Looking ahead
The Tribunal’s full statement of reasons, when published, will clarify the extent of domestic producer participation and the precise basis on which the Tribunal concluded that support was lacking. That document is worth waiting for, because it will indicate whether this was a case of total non participation or of participation judged insufficiently substantive, and those are meaningfully different situations.
More broadly, the decision is a data point in a larger question about what Canada’s solar industrial policy actually is. The country has supported domestic manufacturing through procurement preferences and program design, has maintained trade remedies for over a decade, and has now allowed one of the principal remedies to lapse for want of anyone willing to defend it. Whether that reflects a deliberate policy shift, a natural evolution in industry structure, or simply the arithmetic of litigation costs at individual firms is not yet clear from the public record.
What is clear is that the cost structure of Canadian solar procurement changed on September 17, that the change was confirmed to the importing community on September 22, and that Canadian buyers of photovoltaic modules are operating in a materially different market this week than they were last week.