Proc 11052ProclamationTrump 47 · R Quiet signal

Proclamation 11052

Adjusting Imports of Polysilicon and Its Derivatives Into the United States

This proclamation imposes minimum import prices (MIPs) and a 15% ad valorem tariff on polysilicon and downstream derivatives (ingots, wafers, solar cells, modules) effective December 4, 2026, to protect U.S. production capacity for semiconductor and solar supply chains. It also establishes an onshoring incentive program with construction deadlines by January 20, 2029, and includes differentiated tariff treatment for certain trading partners including the UK (10% rate) and EU/Japan/Korea/Taiwan/Switzerland/Liechtenstein (capped at 15% combined with Column 1 duties).

Impact dates

  1. MIP program and 15% ad valorem tariffs take effect on goods entered for consumption

  2. Construction start deadline for approved onshoring plans

Market exposure

Policy exposure mapping — not investment advice. Illustrative public companies are incomplete and not recommendations.

Mechanisms

Minimum import priceTariffSubsidy / incentiveProcurement

Role pressure

  • ProtectiveDomestic producerMIPs and tariffs create protected domestic market; onshoring incentives directly subsidize U.S. facility investment
  • AdverseImporterMust pay MIP-level prices or specific tariffs; permanent ban for noncompliance; documentation burden
  • MixedDownstream manufacturerSemiconductor makers gain supply security but face higher input costs; solar manufacturers face cost pressure but may benefit from onshoring incentives
  • AdverseProject developerSolar project developers face $0.22/W cell and $0.38/W module MIPs plus 15% tariffs, increasing project costs
  • ProtectiveEquipment supplierOnshoring plans allow duty-free import of production equipment during construction period
  • MixedTrading-partner exporterEU/JP/KR/TW/CH/LI face 15% cap; UK faces 10%; others face full 15% plus MIPs; equivalent MIP adoption can alter applicability

Exposure dates

  • MIP program and 15% ad valorem tariffs take effect on goods entered for consumption
  • Construction start deadline for approved onshoring plans

Illustrative public companies

Curated watchlist matches by sector/role — incomplete; not a recommendation.

ALBAlbemarleAAAlcoaAMATApplied MaterialsASMLASMLAVGOBroadcomCSIQCanadian SolarCENXCentury AluminumCLFCleveland-CliffsDQDaqo New EnergyENPHEnphase EnergyFSLRFirst SolarFCXFreeport-McMoRanINTCIntelQQQInvesco QQQ TrustJKSJinkoSolarMUMicron TechnologyMPMP MaterialsNUENucorNVDANVIDIASQMSQMRUNSunrunTSLATeslaTSMTSMCXUnited States Steel

Confidence: high · Policy alerts

Key directives

  • Establish MIP at $21/kg for polysilicon, $100/kg for ingots/wafers, $0.22/W for solar cells, $0.38/W for solar modules
  • Impose 15% ad valorem duty on polysilicon derivatives effective December 4, 2026
  • Secretary authorized to adjust MIPs based on market conditions
  • CBP shall implement documentation requirements for MIP compliance at entry
  • Permanent import prohibition for materially noncompliant importers and affiliates
  • Secretary authorized to establish onshoring incentive program with company-specific deals
  • Construction must start by January 20, 2029 for approved onshoring plans
  • Tariff offsets for approved onshoring plans contingent on progress and using U.S. polysilicon
  • Retroactive rescission of tariff benefits for fraud or deliberate misrepresentation
  • UK receives 10% rate; EU/Japan/Korea/Taiwan/Switzerland/Liechtenstein receive 15% cap on combined Column 1 and section 232 duties
  • Manufacturing drawback available for Trade Agreement Partners meeting polysilicon content rules
  • Supersession of inconsistent prior proclamations and Executive Orders

Who is ordered

Timeline

Immediate

  • Proclamation signed and published
  • MIP and tariff rates announced ($21/kg polysilicon, $100/kg ingots/wafers, $0.22/W cells, $0.38/W modules, 15% ad valorem on derivatives)
  • CBP authorized to begin compliance planning
  • Stockpiling monitoring begins

Near term (90d)

  • Federal Register notices for HTSUS modifications
  • Onshoring plan solicitation and guidance development
  • Trading partner negotiations on equivalent MIPs

Long term

  • December 4, 2026: MIP program and 15% tariffs take effect at 12:01 a.m. ET
  • January 20, 2029: Construction start deadline for approved onshoring plans
  • Ongoing: MIP adjustments by Secretary based on market conditions
  • Ongoing: Monitoring of import levels and national security threat assessment

Risks & tensions

  • Solar project developers face cost increases from MIPs and tariffs, potentially slowing clean energy deployment
  • Semiconductor industry may face higher input costs if domestic polysilicon capacity does not scale quickly
  • China-dependent supply chains face severe disruption; China not explicitly named but implied as primary target given market share data
  • Retroactive rescission authority creates legal uncertainty for companies investing based on tariff offsets
  • Differential treatment of UK (10%) vs EU/Japan/Korea (15% cap) may create trade tensions with allies
  • MIP adjustment authority provides flexibility but creates policy uncertainty for investors
  • Stockpiling enforcement before December 4, 2026 effective date may be challenged
  • Onshoring program success depends on Secretary's discretion and company compliance monitoring
Proclamation 11052: Adjusting Imports of Polysilicon and Its Derivatives Into the United States · Executive Orders