Statement of Reasons—Expiry review determination: Photovoltaic modules and laminates (SML 2026 ER)

Inclusions, exclusions and additional information

[14] For a full list of inclusions, exclusions and for additional product information please see the relevant sections on the Measures in Force.

Administrative record

[27] The information considered by the CBSA for purposes of this expiry review investigation is contained on the administrative record. The administrative record includes the information on the CBSA’s Exhibit Listing, which is comprised of the CITT’s administrative record at initiation of the expiry review, CBSA exhibits, and information submitted by interested persons, including information which parties feel is relevant to the decision as to whether dumping and/or subsidizing is likely to continue or resume if the order is rescinded. This information may consist of expert analyst reports, excerpts from trade magazines and newspapers, orders and findings issued by authorities of Canada or of a country other than Canada, documents from international trade organizations and responses to the ERQs, if any.

[28] The CBSA sets a date after which no new information submitted by interested parties will be placed on the administrative record or considered as part of the expiry review, also referred to as the “closing of the record date.” For this expiry review, the closing of the record date was March 25, 2026. This deadline allows parties time to prepare their case briefs and reply submissions based on the information on the administrative record.

Export orientation and domestic market conditions in China

[32] Chinese producers of PV modules have more production capacity to levels that substantially exceed both domestic and global demand. Available data indicates that China’s PV production capacity in 2024 exceeded 200% of global demand, demonstrating a structural surplus and a high degree of reliance on export markets.^{Footnote 15}

[33] Despite weakening prices, exports of PV products from China continued to increase. Export volumes of wafers, cells and modules increased by 34.7%, 30.4% and 18.3%, respectively.^{Footnote 16} At the same time, the export value of wafers, cells and modules year-on-year decreased by 31.8% for wafers, 24.5% for cells and 24.7% for modules.^{Footnote 17} This divergence between rising export volumes and declining export values reflects a substantial decline in global photovoltaic prices and indicates that Chinese producers have continued to ship increasing quantities of product at lower prices in order to place surplus production.

[34] This pricing behaviour indicates a willingness by Chinese producers to compete aggressively on price in order to place excess volumes, rather than reduce production. PV module manufacturing and production capacity has experienced a general change in the technology and in the global market, prompting pricing strategy adjustments in order to remain competitive and sustain production levels amid shifting demand patterns.^{Footnote 18}

[35] Conditions in the domestic Chinese PV market further reinforce this export orientation. Policy developments such as distributed power generation management measures and market-based reforms of on-grid electricity pricing introduced uncertainty into the photovoltaic sector.^{Footnote 19} Due to the time lag between the introduction of these policies and the specific implementation measures of various provinces, there was a degree of “wait and see” sentiment in the industry, which increased the uncertainty of the 2025 installed capacity forecast.^{Footnote 20}

[36] Available reports indicate that Chinese domestic demand for PV modules is forecasted to decline in upcoming years. While China was responsible for 64% of the world’s utility-scale solar and wind construction, with 339GW hours of renewable energy infrastructure in progress, recent performance figures reflect a period of peak expansion.^{Footnote 21} In 2024, China’s newly installed PV capacity reached 277.57GW in that year, with a year-on-year growth rate of 28.3%.^{Footnote 22} Despite these historical results, industry forecasts indicate that domestic installation growth is expected to decelerate as market saturation, policy uncertainty, and grid integration constraints persist.

[37] Weakening domestic demand conditions, when combined with unprecedented levels of production capacity, are likely to increase the reliance of Chinese producers on export markets. As domestic demand growth slows, producers are expected to seek alternative markets in order to maintain production levels, manage inventories, and mitigate financial pressures. In the absence of the Canadian measures, Canada would represent an available and relatively open market for redirected exports.

Trade measures in other jurisdictions

[38] In 2013, the European Union (EU) had imposed provisional anti-dumping duties on PV modules and laminates from China.^{Footnote 23} While those measures have since expired, EU courts have confirmed that duties applicable prior to their expiry are legally enforceable where breaches of undertakings are established, suggesting that the termination reflected policy considerations rather than a determination that China’s dumping or subsidization had ceased.^{Footnote 24}

[39] Other measures relating to PV modules and laminates include Brazil imposing a 12% import tax, effective February 2024.^{Footnote 25} The U.S. imposition of anti-circumvention measures against China on PV modules through South-East Asian countries further signifies the extent to which Chinese producers have altered export routes and supply chains to maintain access to major markets in the presence of trade remedies.^{Footnote 26}

[40] In 2024, the U.S. continued prior anti-dumping duties on the subject goods from China.^{Footnote 27} In 2025, India imposed similar anti-dumping measures on solar cells and modules originating in or exported from China.^{Footnote 28}

[41] The CBSA considers that restrictions on PV products from China in other major markets would likely increase incentives to redirect exports to Canada in the event of revocation, rendering the Canadian market relatively more attractive.

International market conditions

[42] The current international market for PV modules and laminates will continue to grow; evidence on record suggests that global newly installed PV capacity was expected to reach 596 GW in 2025, with a year-on-year growth rate of 6%.^{Footnote 29} The PV industry has entered a mature stage of development, demonstrating strong market potential and industry resilience. However, the glut of Chinese solar panels, paired with heightened competition among Chinese manufacturers, dropped the average cost of modules to US$0.098-0.109 in late 2024 to early 2025, marking it “one of the most intense oversupply cycles in history”.^{Footnote 30}

[43] Moreover, information on the record indicates that multiple jurisdictions are advancing energy transition initiatives and expanding renewable-energy deployment. For example, India is undergoing the most transformative energy transition in recent years. As of early 2026, India’s total renewable energy capacity reached about 267GW, with solar accounting for an estimated 144GW of this capacity.^{Footnote 31} This expansion reflects the increasing role of solar energy in national energy strategies and underscores the continued long-term demand for photovoltaic products in global markets.

[44] Industry forecasters predict an overall optimistic growth for the solar industry in the medium-term. The International Energy Agency (IEA) reported that growth in utility-scale and distributed solar PV capacity over the 2025-2030 period is expected to exceed growth observed during 2019-2024 and to account for a substantial share of worldwide renewable-electricity expansion.^{Footnote 32}

[45] While demand is expected to grow globally, the record indicates that supply growth from China has outpaced demand growth, contributing to persistent oversupply and elevated competitive pressure in international markets. In the context of excess global supply and declining prices, producers seeking to maintain production levels may be increasingly inclined to compete on price in export markets, including Canada, should the Canadian measures be revoked.

Determination: Dumping

[46] Based on the evidence on the record, it is recommended that the CBSA determine that the expiry of the order is likely to result in the continuation or resumption of dumping of photovoltaic module and laminate goods originating in or exported from China.

Nature and continued availability of subsidy programs

[50] In the original investigation, the CBSA identified 349 subsidy programs administered by different levels of the Government of China.^{Footnote 33} The Government of China submitted no information for subsidy programs identified by the exporters and only referenced exporter responses in their answers. In the previous expiry review, the Government of China did not provide a response to the ERQ, nor did the Government of China provide a case brief or reply submission.^{Footnote 34}

[51] The absence of updated information from the Government of China indicates that the subsidy programs previously found to be actionable remain in place and available to producers and exporters of the subject goods. In the absence of evidence demonstrating that those programs have been terminated, substantially modified, or rendered ineffective, the CBSA considers that the original findings regarding the nature of subsidization remain relevant.

[52] Recent expiry reviews conducted by the CBSA concerning goods imported from China have determined that the expiry of the finding is likely to result in the continued subsidizing of the goods if the findings were rescinded. Reviews concluded on December 24, 2025 and March 9, 2026, for concrete reinforcing bar and oil country tubular goods respectively, indicated a likelihood of continued subsidization.^{Footnote 35}

[53] Since the issuance of the CITT’s order, the CBSA has not conducted any re-investigations to update amounts of subsidy for photovoltaic modules and laminates. The CBSA has conducted additional subsidy investigations involving China, which bring the current total to 31 countervailing measures in force applicable to Chinese goods sold to Canada.^{Footnote 36}

[54] In light of the extensive number of subsidy programs previously identified, the absence of evidence demonstrating their elimination or withdrawal, the continued non-cooperation of the Government of China, and the CBSA’s recent findings of likely continued subsidization in other expiry reviews involving goods from China, the CBSA considers that subsidization of photovoltaic modules and laminates would likely continue or resume if the countervailing measure were revoked.

Global countervailing measures

[55] In 2024, the U.S. continued prior countervailing duties on the subject goods from China.^{Footnote 37} In 2025, India imposed similar countervailing duties on solar cells and modules originating in or exported from China.^{Footnote 38}

[56] The U.S. Department of Commerce (DOC) recently issued final determinations concerning crystalline silicon photovoltaic cells, whether or not assembled into modules, exported from Cambodia, Malaysia, Thailand, and Vietnam. The U.S. authorities found that producers and exporters of the goods received countervailable subsidies from the Government of China, notwithstanding that production and assembly occurred in third countries.^{Footnote 39} In certain cases, the countervailing duty rates had subsidy margins exceeding several hundred percent, including where adverse facts were applied for non-cooperation.

[57] These findings demonstrate that Chinese government subsidization of photovoltaic production is not limited to facilities located within China, but may extend to upstream inputs, financing, ownership structures, and other forms of support that benefit Chinese-owned or controlled producers operating abroad. In the absence of Canadian measures, such subsidized production would be capable of supplying the Canadian market directly or indirectly at prices that do not reflect market-determined costs.

Role of the Government of China and industrial policy on PV modules and laminates^{Footnote 40}

[58] The scale of subsidization in China’s solar sector has generated sustained imbalances between supply and demands and financial hardship for the industry. The OECD found that in the past two decades, continued investment in module production capacity had gone beyond current and projected global demand levels, mainly in China and particularly between 2019 and 2024, while the average selling price dropped dramatically from 2008 onwards. The decline in prices was so extreme that in 2024, they averaged a level below the break-even point for several Chinese firms.

[59] Consequently, Chinese producers have either exited the market, downsized operations or were bought-out by competitors. This outcome is indicative of a market structure sustained by state intervention, where the availability of government support has enabled the continuation and expansion of capacity despite persistent losses and weak commercial fundamentals.

[60] According to the IEA, China’s share of global manufacturing capacity is estimated to be 80%-95%, depending on the segment of the value chain. Such concentration raises trade and competition concerns and heightens the risk of value-chain disruption for downstream industries and importing countries.

[61] The CBSA considers that, absent the Canadian countervailing measure, the continued role of the Government of China and its industrial policy objectives would support the availability and use of subsidies that benefit producers of photovoltaic modules and laminates.

Determination: Subsidy

[62] Based on the evidence on the record, it is recommended that the CBSA determine that the expiry of the order is likely to result in the continuation or resumption of subsidizing of photovoltaic module and laminate goods originating in or exported from China.