On February 6, 2026, the Section 201 tariffs on imported solar panels expired — ending an 8-year duty regime that began at 30% in 2018 and reached 14% in its final year. At the same time, new FEOC (Foreign Entity of Concern) restrictions took effect January 1, 2026, splitting the commercial solar market into two tiers: panels with FEOC-compliant, domestically-sourced supply chains command a price premium and unlock the +10% Domestic Content Bonus, while non-compliant panels are cheaper but ineligible for the bonus credit stack. This is the most significant shift in US solar panel trade policy since 2018.
What Were the Section 201 Solar Tariffs?
Section 201 tariffs were duties levied on most imported solar panels under the 1974 Trade Act's safeguard provisions. The first Trump administration imposed them in January 2018 at a 30% rate, citing harm to US solar manufacturers from a surge of imports — primarily Chinese cells and modules routing through Southeast Asian assembly. The rate stepped down each year, was extended for four years by the Biden administration in 2022, and reached 14% before expiring on February 6, 2026.
The tariffs originally targeted crystalline silicon photovoltaic cells and modules, with bifacial panels held in contested exemption status throughout most of the policy's life. While Section 201 succeeded in onshoring meaningful US module-assembly capacity — most visibly QCells' Dalton, Georgia facility, plus expansions by Silfab, Mission Solar, and a wave of new Inflation Reduction Act-era greenfield announcements — it never closed the gap on cells, wafers, polysilicon, or core capital equipment, all of which remained China-dominated.
For commercial buyers comparing the major Tier-1 brands, this gap matters less than it did under the IRA-only regime: the FEOC framework now penalizes a much broader category of upstream-Chinese supply than the Section 201 tariffs ever did. See our updated best solar panels 2026 ranking for current Tier-1 comparisons including which brands carry full upstream domestic content.
The Section 201 expiration arrived as the FEOC framework — codified in 2026 ITC regulations — went live, in effect replacing one form of import deterrence (a tariff) with another (loss of credit eligibility). For commercial buyers, the practical impact of that swap is significant: panels are no longer taxed at the border, but choosing a panel with significant Chinese supply-chain involvement now reduces your accessible federal credit pool. The economics of the procurement decision have inverted from what they were in 2024.
What Does the Tariff Expiration Mean for Panel Prices?
For non-FEOC-compliant panels — those with predominantly Chinese supply chains routed through Southeast Asia — the Section 201 expiration removes about 14% of landed cost, modestly cheapening this tier. For FEOC-compliant, domestic-content panels, prices have not fallen — and in many cases have risen — because demand outpaces supply. The result is a market where the cheapest panels and the most tax-credit-efficient panels are different products entirely.
It's tempting to treat the tariff expiration as a flat price cut. The reality is that modules represent only a portion of installed commercial solar cost — typically 20–30% in 2026 — and labor, racking, electrical, permitting, and interconnection are larger drivers of the overall bill. SEIA's Q4 2025 Solar Market Insight Report puts year-over-year commercial solar installation cost growth at roughly 9%, driven largely by labor and soft costs — not module pricing.
Bottom line for commercial procurement: hardware deflation from tariff expiration is real but small relative to overall project cost, and it is more than offset for credit-maximizing buyers by the premium on FEOC-compliant panels. For a current 2026 ranking of Tier-1 panels with Domestic Content qualification status, see our guide to which solar panels qualify for domestic content bonus credits. Maxeon, REC, and QCells are the three Tier-1 mainstream options; QCells is the only one of the three with full US cell-and-module manufacturing and a clear path to Domestic Content qualification in 2026.
One nuance commercial buyers consistently get wrong: the Domestic Content Bonus is calculated as a percentage of the entire project's eligible basis, not just the panel cost. That makes "small" decisions on inverters, racking, and balance-of-system steel disproportionately important — a project that gets panels right but specifies imported racking can fail the threshold and lose the full +10% bonus. Reputable commercial solar contractors will model the BOM holistically rather than picking modules in isolation; insist on a written certification of expected Domestic Content percentage before signing a procurement contract.
What Are FEOC Rules and Why Do They Matter?
FEOC stands for Foreign Entity of Concern — a category of foreign-government-influenced entities (China, Russia, Iran, North Korea) defined under federal law. Beginning January 1, 2026, projects that incorporate "material assistance" from FEOCs may not qualify for the full ITC and bonus stack. Choosing FEOC-compliant panels — most commonly US-manufactured panels like QCells from Georgia — unlocks the 10% Domestic Content Bonus on top of the 30% base ITC, often reducing net project cost by 5–10% versus a non-compliant alternative.
Three sets of components face FEOC scrutiny in commercial solar: the panel itself (cells, wafers, polysilicon, frame, glass), the inverter (silicon controllers and capacitors), and the racking / balance-of-system steel. Of these, panels are the highest-stakes choice — they represent the largest dollar commitment and are the input most likely to trigger a FEOC determination if sourced from China.
The "material assistance" standard is more nuanced than a pure country-of-final-assembly test. A panel that is assembled in Vietnam from cells produced in China by a company with significant Chinese-government ownership can still trigger FEOC issues — even if the module-level country of origin is reported as Vietnamese. That is why competent commercial solar contractors require manufacturer attestations covering the full upstream supply chain, not just the country of final assembly. Without that documentation, the IRS audit risk on credits claimed years later is non-trivial.
How to Verify FEOC Compliance Before Purchasing Panels
- Ask the manufacturer for bill-of-materials documentation identifying the country of origin for cells, wafers, polysilicon, frame, glass, and major balance-of-system components.
- Confirm polysilicon source is not Xinjiang or any FEOC nation. Polysilicon is the input most often associated with sanctioned Chinese facilities; reputable manufacturers will provide signed attestations on request.
- Request an installer-level certification of Domestic Content qualification, including the percentage of US-manufactured content in the proposed bill of materials.
- Retain documentation for at least seven years — IRS audit windows can reach six-plus years, and FEOC compliance attestations are likely to face heightened scrutiny.
For region-specific commercial buyer guidance in markets where FEOC-compliant supply has been most challenged, see our guide to commercial solar companies in Illinois.
The Two-Tier Solar Market in 2026
The Section 201 expiration plus FEOC enforcement has produced a clear two-tier market. Tier 1 — FEOC-compliant, domestic-content panels — costs more per watt up front but unlocks 40–50% of project cost in stacked federal incentives. Tier 2 — non-compliant, cheaper panels — has a lower hardware cost but ineligibility for bonus adders and exposure to pending Section 232 polysilicon tariffs that could re-tax these imports mid-project.
| Tier | Cost / Watt | Domestic Content Bonus | Total Federal Stack | Effective Net Cost |
|---|---|---|---|---|
| Tier 1 (FEOC-compliant, US content) | $0.32–$0.42/W | Eligible (+10%) | 40–50% with adders | Lowest after credits |
| Tier 2 (non-compliant, imported) | $0.24–$0.30/W | Not eligible | 30% base only | Higher after credits + tariff risk |
The headline number that matters: even with Tier-1 panels costing 25–40% more per watt at the module level, the after-credit project cost is typically lower because the +10% Domestic Content Bonus applies to the entire installed cost — not just the panel. On a $200,000 project, that bonus alone is $20,000 — far more than the marginal premium on the panels themselves.
Commercial buyers in Florida commercial solar markets — where FEOC-compliant supply has been competitive in 2026 — are already seeing this dynamic dominate procurement decisions. A Section 232 polysilicon investigation, initiated in mid-2025 by the Department of Commerce, remains pending; an affirmative determination would impose national-security tariffs on all panels containing non-domestic polysilicon, further widening the cost spread between the two tiers.
What New Tariff Cases Are Still Pending?
Three significant tariff actions remain pending in 2026: a new Antidumping/Countervailing Duty (AD/CVD) petition against solar imports from India, Indonesia, and Laos (decision expected mid-2026); the Section 232 polysilicon national-security investigation (timing uncertain); and routine bifacial and cell-tier exemption reviews. Together, these create real downside risk for commercial buyers who delay equipment procurement: a project that contracts panels in mid-2026 could see those panels become subject to new duties before delivery.
The pending cases break down as:
- AD/CVD India / Indonesia / Laos. The Alliance for American Solar Manufacturing has petitioned the Department of Commerce alleging unfair pricing and subsidies on imports routed through these countries. Preliminary determinations could come mid-2026; final determinations typically follow within 6 months. If affirmative, duties of 30–280% could attach.
- Section 232 polysilicon. Initiated July 2025 by the Department of Commerce. A national-security finding would impose tariffs on all panels containing non-domestic polysilicon — including many "Made in Vietnam / Cambodia" modules currently used in commercial-scale projects.
- Bifacial and cell-tier reviews. The expired Section 201 framework had complex bifacial exemption rules; new policymakers may revisit the precedent in any successor action.
The bottom line for procurement: locking in panel orders now — under the 5% safe-harbor framework that also satisfies the OBBBA July 4 ITC deadline — protects against both the policy-loss risk of missing the ITC and the cost-rise risk of new tariffs attaching mid-project.
Buyers comparing AD/CVD risk against tariff savings should also note that AD/CVD duties are typically retroactive to the petition date once a final affirmative determination issues. That means panels imported under apparent duty-free terms in early 2026 could be hit with retroactive duties later in the year if the Commerce Department finds for the petitioner — exposing buyers who deferred procurement to a worst-of-both-worlds outcome. The 5% safe-harbor framework, by contrast, locks in the panel price at contract — leaving the supply chain risk with the manufacturer, not the buyer.
How to Buy Smart in 2026 — A Commercial Buyer's Checklist
The smart 2026 commercial solar buyer maximizes ITC and bonus credits while shielding against tariff risk by acting fast, choosing FEOC-compliant equipment, and documenting compliance carefully. Six steps separate a low-cost, fully-credited project from one that leaves money on the table.
Six Steps to Buy Smart in 2026
- Begin construction before July 4, 2026 to lock in 30% ITC eligibility — using either the physical-work or 5% safe-harbor route.
- Request FEOC compliance documentation from your installer and panel manufacturer before signing any contract.
- Ask specifically about Domestic Content Bonus eligibility — confirm the bill-of-materials percentage and require it in writing.
- Get equipment contracted now to avoid the risk of pending tariff cases attaching duties mid-project.
- Verify installer ITC documentation experience with at least three commercial reference projects of similar scope.
- Compare QCells (Dalton, GA) and other FEOC-compliant panels for the Domestic Content Bonus — Maxeon and REC are also Tier-1 but currently do not qualify for the full bonus on US-deployed projects.
To execute this checklist, find a verified commercial solar installer in your state and pair the search with the homeowner-style vetting playbook in our guide on how to find a reputable solar company — the same principles apply to small and mid-size commercial buyers.
References
Frequently Asked Questions
Did the solar panel tariffs end in 2026?
Yes — the Section 201 tariffs on imported solar panels expired February 6, 2026 for the first time in eight years. The tariffs began at 30% in 2018 under the first Trump administration, were extended by President Biden in 2022, and stepped down each year before reaching 14% in 2025 and expiring in early 2026.
What is the FEOC rule for solar panels in 2026?
FEOC (Foreign Entity of Concern) rules took effect January 1, 2026 and restrict full ITC eligibility for commercial solar projects that include "material assistance" from China, Russia, Iran, or North Korea. Choosing US-manufactured panels — most prominently QCells from Dalton, Georgia — unlocks the +10% Domestic Content Bonus and avoids FEOC restrictions.
Are solar panels getting cheaper or more expensive in 2026?
It depends on which panel tier you buy. Non-FEOC-compliant panels are slightly cheaper after the Section 201 tariff expired in February 2026. FEOC-compliant, domestic-content panels are often more expensive due to demand outpacing US-manufactured supply — but they unlock the +10% Domestic Content Bonus, which usually more than offsets the premium on the after-credit basis.
What is the Section 232 polysilicon investigation?
The Section 232 polysilicon investigation is a US Department of Commerce national-security review initiated in July 2025. An affirmative determination would impose tariffs on all solar panels containing non-domestic polysilicon — including many "Made in Vietnam / Cambodia" modules currently popular in commercial-scale projects. The decision timing is uncertain.
Which solar panels qualify for the domestic content bonus credit?
Solar panels qualify for the 10% Domestic Content Bonus when their cells, wafers, polysilicon, frame, and glass meet US-content thresholds defined in IRS regulations. In 2026 the most reliable mainstream option is QCells modules manufactured at the Dalton, Georgia facility. Maxeon and REC are also Tier-1 brands but currently do not qualify for the full domestic content stack on US-deployed projects.
Is QCells made in the USA?
Yes — QCells operates the largest fully-integrated solar manufacturing complex in the Western Hemisphere at Dalton and Cartersville, Georgia. As of 2026, the facility produces both cells (Cartersville) and modules (Dalton), making QCells panels the leading FEOC-compliant, Domestic Content Bonus-eligible option in commercial solar.
How do tariff changes affect my commercial solar project cost?
For 2026 commercial buyers, the net effect of the Section 201 expiration and FEOC framework is a two-tier market. Hardware deflation from tariff expiration is real but small (~14% off the imported tier) relative to total project cost — modules are only 20–30% of installed commercial solar pricing. The bigger effect is the +10% Domestic Content Bonus, which can swing project economics by tens of thousands of dollars on mid-size commercial.
What AD/CVD tariff cases are pending against solar imports in 2026?
In 2026, the Alliance for American Solar Manufacturing has petitioned the US Department of Commerce for Antidumping/Countervailing Duties on solar panel imports from India, Indonesia, and Laos. Preliminary determinations are expected mid-2026; if affirmative, duties of 30–280% could attach. A separate Section 232 polysilicon investigation is also pending and could impose national-security tariffs on a broader set of imports.