Solar Panel Production in South Carolina FTZ: Understanding the Trade Rules

You might care about this because the US government is considering a request from Translucent Solar, LLC to produce solar panels within Foreign-Trade Zone 21 in Summerville, South Carolina. A Foreign-Trade Zone is a special area within the United States that is treated as being outside US customs territory for some purposes. This means companies can bring foreign goods into the zone without paying duties until those goods leave the zone and enter the US market. Translucent Solar plans to make solar photovoltaic modules. These modules are basically solar panels made from connected monocrystalline silicon cells sealed between layers of glass, framed with aluminum, and including a junction box. They will use imported materials like different types of solar glass and G12 or G12R monocrystalline heterojunction cells. Some of these imported materials, depending on their origin, are currently subject to certain import duties under Section 301 of the Trade Act of 1974. Also, crystalline photovoltaic cells from India may be subject to antidumping or countervailing duties. To handle these duties, the company must bring these specific materials into the FTZ under a status called "privileged foreign" status. This status means that the materials keep their original foreign classification and duty rate even after being processed in the zone. This can affect how duties are paid when the final solar panels are sold in the US or exported. The public has until September 16, 2026, to comment on this proposed activity. This announcement is interesting because it clearly illustrates how companies use Foreign-Trade Zones to deal with specific trade rules and duties. For instance, Translucent Solar wants to use materials that are subject to Section 301 duties. These are extra taxes the US imposes on goods from certain countries. The document explains that these materials must enter the FTZ under "privileged foreign" status. This status is a key part of how FTZs work. It allows companies to decide whether to pay duties on the raw materials as they enter the zone, or on the finished product when it leaves the zone for the US market. This can save money, especially if the finished product has a lower duty rate or if the raw materials are exported without entering the US market. The document also mentions anti-dumping and countervailing duties on solar cells from India. These are duties put in place to prevent unfair pricing practices. The rules for FTZs ensure that even goods subject to these special duties are handled correctly. This case shows how these complex trade rules are put into practice for a specific manufacturing project in the solar energy sector. It highlights the balance between promoting US manufacturing and addressing trade concerns. Many different groups would find this legal document interesting. First, companies that manufacture products in the United States, especially those using imported parts, should pay attention. This includes businesses in the solar energy industry, as the document directly concerns solar panel production. Any manufacturer considering setting up operations in a Foreign-Trade Zone would also want to review this. It provides a real-world example of how FTZ rules apply to goods with special duties. Importers and exporters of goods subject to Section 301 duties or anti-dumping/countervailing duties would find the details about "privileged foreign" status particularly useful. This status can greatly affect their costs and supply chain strategies. Trade attorneys, customs brokers, and consultants who advise businesses on international trade and customs compliance should also read this. It offers a practical look at how these regulations are applied. Finally, anyone interested in economic development in South Carolina, especially Summerville, might find this relevant. It signals new manufacturing activity and job creation in the area.