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The Bottom Line
On August 6, the President invoked Section 232 on polysilicon. The measure sets minimum import prices for polysilicon, ingots, wafers, solar cells, and solar modules, and adds a 15% tariff on downstream products starting December 4. Quartz countertops are the more immediate change, with a separate Section 201 safeguard taking effect August 15. The four-year tariff-rate quota runs from 25% within the quota to 50% above it. Commerce is also proposing 14 more categories, from tanker trailers to fire extinguishers, for the steel, aluminum, and copper tariffs, with comments due August 27.
Importers of polysilicon, solar cells, solar modules, and the ingots and wafers between them face a new price floor. On August 6, the President signed Proclamation 11052 under Section 232. It sets minimum import prices of:
The floor takes effect December 4. There's also a 15% tariff on downstream derivatives, effective the same day.
If an entry comes in below the floor, the specific tariff is the difference. No price certification means the tariff equals the entire floor.
Manufacturing drawback is available on these duties, but the conditions are narrow. The article can't sit under an antidumping or countervailing duty order. Its polysilicon also has to come entirely from a trade-agreement partner such as the UK, the EU, Japan, Korea, Canada, or Mexico.
The proclamation ties polysilicon to more than just solar as it points to its use in semiconductors, defense, and AI. It also notes that the U.S. share of global polysilicon capacity fell from 50% in 2005 to less than 2% in 2024.
The price floor changes the sourcing math because the entered value cannot fall below the minimum, even if the importer paid less.
Price certification is another thing to watch. If an importer submits materially inaccurate price documentation, it and its affiliates can be barred from importing polysilicon.
Source: Federal Register, August 11, 2026 (91 FR 51975)
Imported quartz surface products (the engineered stone commonly used for countertops) will face a new Section 201 safeguard starting August 15. Proclamation 11051 sets a four-year tariff-rate quota, with a 25% tariff on imports within the quota and 50% on anything above it.
The rates come down over four years, reaching 19% within quota and 47% over quota in year four. The quota is split into quarterly amounts, with a first-year cap of about 13 million square meters.
For goods placed in a foreign trade zone on or after August 15, importers have to use privileged foreign status. Placing the goods in a zone will not delay the duty.
Canada, Mexico, Korea, Israel, Australia, and the CAFTA-DR countries are excluded. Developing countries are also excluded if each accounts for less than 3% of imports and they stay below 9% combined.
Commerce is proposing 14 more product categories for the Section 232 tariffs on steel, aluminum, and copper. The list includes aluminum powder and brass instruments, as well as fire extinguishers, floor safes, electric conductor cables, tanker trailers, and farm trailers. Comments are due August 27.
Most of the products would face a 25% tariff. Farm trailers that load or unload themselves would be treated as agricultural equipment and face 15%. Filled steel canisters of propane, oxygen, and propylene would face 50%, but only on the value of the metal container, not the contents.
The rate is based on the metal content, so classification matters. It's worth checking whether any products fall under the listed HTS codes before the August 27 deadline.
Source: Federal Register, August 6, 2026 (91 FR 50756; regulations.gov docket BIS-2026-0331)
Aluminum can stock. Commerce moved to revoke in part the antidumping and countervailing duty orders covering certain aluminum can stock from 17 countries. If finalized, the change would remove those duties from the covered products. Commerce is accepting comments on the preliminary results. 91 FR 51666
LCD glass substrates. The ITC issued a limited exclusion order and a cease-and-desist order in a Section 337 case involving glass substrates for liquid crystal displays. The orders block infringing imports and name a U.S. distributor. Importers of affected displays should review whether they are covered. 91 FR 51744
Review quartz surface lines before August 15
Pull any lines under HTS 6810.99.0020, 6810.99.0040, or 7020.00.6000 and check the origin against the exclusion list. If you have FTZ stock, check that too. Privileged foreign status will lock in the safeguard.
Comments on the 232 derivative list are due August 27
If you import any of the 14 proposed categories, including tanker trailers and fire extinguishers, comments can be submitted through regulations.gov under docket BIS-2026-0331. It's worth running the numbers at the proposed 25%, 15%, and 50% rates to see what the impact could be.
Review polysilicon and solar lines before December 4
Check your polysilicon, ingot, wafer, solar cell, and module prices against the new minimums. If the price is below the floor, the difference becomes duty. Manufacturing drawback may be available for qualifying sourcing from trade-agreement partners.
Reach Out to Caspian to Understand Your Impact
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