Canada Removes Anti-Dumping Duties on Chinese Solar Modules: Charge Solar’s Perspective

Executive Summary

• On September 17, 2026, the Canadian International Trade Tribunal rescinded with immediate effect the anti-dumping and countervailing duties on photovoltaic modules made in China which had been in place since 2015.
• Nothing changed regarding certification or import obligations. Most China-origin modules are not certified for use in Canada. For vendors starting now, roughly three months is a realistic, estimated duration to complete certification.
• Early indications suggest module cost reductions in the range of approximately 15% will take effect in early 2027.
• Charge Solar will offer China-origin modules with heavily vetted supply chains and will continue to focus on tier 1 highly bankable manufacturers.
• Our position: Though Charge Solar recognizes the benefits of this change, we would have preferred the duty remain in place at least until rigorous import regulations were published and enforceable. Our ask of government: publish those regulations quickly.

Background

Why the duties existed

In December 2014, the CBSA initiated dumping and subsidizing investigations following a complaint from four Ontario manufacturers — Eclipsall Energy, Heliene, Silfab Ontario, and Solgate — alleging lost sales, price undercutting, declining financial results, and “recent insolvencies and closures.”

On July 3, 2015, the Tribunal found that dumping and subsidizing had not caused injury to the domestic industry but were threatening to and duties were applied.

The domestic industry that prompted the complaint in 2014 looks very different today. This year’s expiry review confirmed that while Heliene has not manufactured modules in Canada since December 2022, it was the only solar manufacturer to respond to the CBSA’s Canadian Producer questionnaire.

What the duties accomplished in practice

The measure was never described as an import ban, but in practice it came close to functioning as one with recent duty rates above 150%. Imports from China fell from 56,603 modules in 2023 to 4,369 in 2024 and 6,284 in 2025, with total SIMA duties of only $3.8 million collected across the three-year review period. These data show that, at those duty rates, the economics of importing Chinese-made modules into Canada simply did not work.

That produced a second-order effect worth understanding; to sell modules into Canada, a Chinese manufacturer had to establish production capacity outside China, decide which products would be built there, and certify those products to Canadian standards. This required substantial capital and a deliberate commitment to a relatively small market.

This is not a claim that production in Vietnam, Malaysia, or elsewhere was necessarily free of supply-chain risk. The barriers of time and capital narrowed the field of manufacturers exporting to Canada, limiting the quantity of potential vendors for Canadians to evaluate, allowing us to delve further into those vendors’ supply chains. That was an incidental filter, never the measure’s stated purpose.

That filter is now gone. A Chinese manufacturer needs only Canadian electrical certification and can leverage existing Chinese factories to produce modules for Canada. With no published import regulations or consistent enforcement practices, vendors will reasonably read Canada as an open market subject to certification alone.

The forced labour framework

Canada’s existing framework is real but narrow and not well documented for importers. In 2020, a forced labour import prohibition was added to the Customs Tariff to meet CUSMA obligations, enforced at the border by the CBSA on a risk-based approach. Canada, the United States, and Mexico remain the only countries with such a prohibition in force; the EU’s is expected by late 2027.

In 2024, Bill S-211, the Fighting Against Forced Labour and Child Labour in Supply Chains Act, came into force, requiring certain entities to report annually on steps taken to prevent or reduce the risk of forced and child labour in their supply chains. Charge Solar has reported under S-211 since 2024, and our annual supply chain reports are published publicly on our website. But S-211 is transparency legislation — it requires disclosure, not adherence to any regulations or standard.

On June 12, 2026, the federal government introduced Bill C-35, which would replace the Customs Tariff prohibition with a standalone statute. As drafted, it would authorize the Minister of Foreign Affairs to establish a public list of high-risk goods by region, entity, or individual, require importers of listed goods to provide enhanced supply-chain tracing information, and deem goods prohibited from importation where those requirements are not met. Charge Solar supports Bill C-35; however, on its own, it is not sufficient without published guidance on how the CBSA will verify that imported goods are compliant. Global Affairs Canada’s own consultation paper acknowledges that forced-labour goods carry no physical indicators distinguishing them at the border, and that there is currently no list of goods, producers, or regions to support proactive, risk-based targeting. Without a documented verification standard, importers cannot know what compliance looks like, and overseas vendors cannot know what will be enforced.

The Decision

The Tribunal initiated its expiry review on February 2, 2026, with the CBSA opening its investigation the following day. On July 2, 2026, the CBSA determined that expiry of the order was likely to result in the continuation or resumption of both dumping and subsidizing.

That determination was well supported with market data. The CBSA found that Chinese PV production capacity in 2024 exceeded 200% of global demand, demonstrating a structural surplus and heavy reliance on export markets. Export volumes rose while export values fell sharply — modules up 18.3% by volume and down 24.7% by value — indicating producers were shipping surplus supply at declining prices rather than reducing output. The agency characterized the period as among the most intense oversupply cycles in the industry’s history. It noted that 349 subsidy programs had been identified in the original investigation with no evidence submitted that any had been terminated, and that the Government of China again declined to respond. The IEA estimates China holds 80–95% of global manufacturing capacity depending on the value-chain segment, while the OECD found 2024 selling prices below break-even for several Chinese firms, with producers exiting, downsizing, or being acquired.

No manufacturers, including Heliene, filed a case brief supporting continuation of the order. On September 17, 2026, the Tribunal terminated the expiry review and rescinded the order — nearly three months ahead of its December 9 deadline.

Our interpretation of the public record is that the order fell because of a lack of a domestic industry to protect and the associated lack of evidence of harm, not because the underlying dumping and subsidy concerns had been resolved. The CBSA had concluded the opposite ten weeks earlier, on a detailed record. Charge Solar’s view is that the duty should have remained in place at least until rigorous import regulations were published and enforceable.

What We Expect

Near term (0–6 months)

• Lack of certified Tier 1 products. Most China-origin modules lack certification for Canada. For manufacturers beginning the process now, roughly three months is a realistic minimum duration to obtain Canadian certification.
• Pricing. Early indications point to reductions of approximately 15% relative to current leading-supplier pricing for comparative quality and bankability. Charge Solar will provide vendor and pricing updates as the market adapts to this change in policy.
• A significant vendor influx. Three forces compound here. Global supply continues to outstrip demand, sustaining pressure on Chinese manufacturers to find markets to place volume. The US market has contracted following the removal of federal ITC support and increased barriers to importation, further constraining global demand. And, in our experience, overseas vendors consistently overestimate the size of the Canadian market.
• A recognition problem. The manufacturers at the top of global bankability rankings are largely not household names in Canada. Installers and end customers will struggle to distinguish durable suppliers from transient ones while relying on 25–30-year warranties.
• Stranded incumbent investment. Suppliers who served Canada in recent years have committed capital to non-Chinese manufacturing, Canadian certification, local staff, and in some cases Canadian warehousing. That capital now competes against product carrying none of those costs.

Medium term (6 months – 2 years)

• Expect vendor attrition. Warranty obligations outlive the companies that issue them, and the OECD data above points to continued consolidation among Chinese producers. Whether Bill C-35 changes the picture depends entirely on whether clear import regulations are published and predictably enforced. If they are, we would expect some re-concentration around suppliers able to document and actively defend their supply chains upon importation into Canada.

Long term (2 years+)

• The open question is where Canada settles between the EU and Australian model on one side and the US model on the other, and whether a published, predictably enforced verification regime emerges. If it does, Canada can benefit from the advantages of global suppliers while ensuring responsible supply chains through inspection and enforcement.

The Advantages, As We See Them

Faster access to current technology. Modules continue to improve materially in efficiency, aesthetics, durability, and reliability. Under the previous policy structure, Canada was not gaining timely access to the most recent innovations since producers in non-Chinese countries would often lag the Chinese-made models.

Lower module cost. This decision improves the levelized cost of energy (LCOE) which matters most in markets with low electricity costs, no incentive programs, or unfavourable utility rate structures. Where the reduction is not passed through to market price, it offers modest installer margin relief. This article focuses on the residential and commercial markets served through distribution, but it is worth noting that for large-scale projects procuring outside distribution channels, these savings are likely to flow through as lower energy prices from developers, reducing the cost of renewable energy for Canadians. This is welcome news at a time when affordability is paramount.

Alignment with peer markets. Canada now sits closer to Australia and Europe policy-wise than to the United States. EU anti-dumping and anti-subsidy measures on Chinese modules expired on September 3, 2018, after the Commission rejected the industry’s expiry review requests. The Commission’s reasoning was that the EU industry had not benefited from the measures and had lost further market share to South-Asian imports, and that continuing them “could have become a barrier to the increase of demand necessary to meet the Union’s targets for renewable energy.” Australia’s Anti-Dumping Commission terminated its investigation into Chinese PV modules in October 2015, finding injury to the domestic industry negligible. The parallels to Canada’s rationale to remove the duty are clear.

The Risks, As We See Them

Fragmentation and loss of supply stability. Many vendors and many SKUs weaken the case for bankable tier 1 suppliers to invest in a Canadian presence which was the very investment that created the continuity of supply that underpinned substantial market growth over the last five years.

Quality risk for limited savings. Modules were already inexpensive under global oversupply and represent a shrinking share of total installed cost. Trading long-term reliability for a small portion of total project cost is a poor exchange across a 25-30-year asset life.

Supply-chain exposure without published verification standards. As described in the Forced Labour Framework section above, Canada has a prohibition and a reporting statute, but no published import regulations and enforcement policy. This is why we would have preferred the import regulations under Bill C-35 to have been completed and published prior to removal of the duty on Chinese-made modules.

Our Ask of Government

The ethical case stands on its own; Canadians should not be unknowing participants in supply chains involving forced labour. But there is also a defensive one: solar industry opponents have used supply-chain concerns to cast doubt on the sector, and transparent import regulations and predictable enforcement are the answer. They convert a contested claim into a documented fact and give the industry something verifiable to point to, rather than an argument to keep having domestically and during international trade negotiations.

We would encourage a two-tier approach:

1. An “every import” requirement. A defined, published set of documentation on every shipment including country of origin at each step of the supply chain, with manufacturer and importer declarations of no forced labour. Bill C-35 supplies the legal framework for consequences where a declaration is later found untrue.
2. A published deeper standard selectively enforced. Full “mine to module” traceability, enforced at the CBSA’s discretion. Selective enforcement is necessary because full traceability is exhaustive for both the importer and the CBSA, but the standard must be published, so vendors understand in advance what may be asked of them before deciding to enter this market.

There is a commercial case alongside the principle. Published rules make border outcomes predictable. Tier 1 suppliers with documented supply chains clear reliably, which means stable and continuous supply for installers, not only ethical assurance.

How Charge Solar Is Responding

Near-term stability through inventory. We are holding market-leading on-hand inventory levels to ensure continuity of supply through this transition.

Continued focus on tier 1 manufacturers at the top of the bankability stack. The same vendors who served Canada from Vietnam, Malaysia, and elsewhere can now also supply their China-built products.

Our position on China-origin product, stated plainly. We believe, with substantial supporting evidence, that China-origin modules can be produced through responsible, documentable supply chains. We will offer them after heavy vetting, because we think it is ethical, and because vendors who cannot document their supply chains risk being held at the border, making them a potential supply-continuity problem.

Continued advocacy and compliance. We intend to participate in ongoing consultations and advocacy relating to import regulations and will continue publishing our annual S-211 reports.

Checklist for Installers

Disclaimer

Charge Solar is not a trade law, customs, or import compliance advisor. The views expressed here are our own interpretation of public records, shared to help clarify a change that affects our customers and how Charge Solar intends to respond to it. Installers should do their own diligence and confirm their own obligations.

Sources

• CITT news release — Tribunal Terminates Expiry Review, September 17, 2026
• CBSA Statement of Reasons — Expiry Review Determination (SML 2026 ER)
• CBSA Notice of Conclusion of Expiry Review Investigation, July 2, 2026
• CBSA initiation of investigations, December 2014
• CITT finding — Threat of Injury, July 3, 2015
• Global Affairs Canada — Bill C-35 backgrounder, June 12, 2026
• GAC/CBSA public consultation on the regulatory approach under Bill C-35
• Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211)
• European Commission — measures on solar panels from China expire, September 2018
• European Parliament — Commission answer on the end of anti-dumping measures

Jeff MacAulay
CEO, Charge Solar