CITT extends anti-dumping order on Chinese solar modules through 2031

CITT order renewed through 2031

On July 2, 2026, the Canadian International Trade Tribunal concluded its expiry review and extended the anti-dumping and countervailing duty order on photovoltaic modules and laminates originating in or exported from China for another five years. The original order dates to March 2021; this extension runs through 2031.

If you import solar equipment, three things matter right now: knowing whether your goods fall under the SIMA order, having defensible HS classification at the six-digit level, and filing accurate origin declarations on every CAD. CBSA has been flagging shipments for verification since February when the review was announced, and we’ve seen release holds stretch three to five business days while the importer scrambles for supplier documentation that should have been on file before the container landed.

What falls under the order

The order covers photovoltaic modules and laminates, which the CITT defines as assemblies of interconnected photovoltaic cells designed to generate electricity from sunlight. If your product includes the cells in a finished assembly ready for installation or integration into a larger system, it’s likely subject goods.

The traps show up at the margins. Importers bringing in laminates for final domestic assembly sometimes assume the goods aren’t finished modules and file under a non-subject HS code. CBSA disagrees, and when they pull the file for a post-release verification, you’re looking at retroactive duty assessments plus interest dating back to the original entry. The Normal Value and subsidy margins vary by exporter, but when CBSA applies the all-others rate, the combined AD/CVD can run 200% or more on the declared value.

If your supplier changed factories, changed export entities, or shifted production between Chinese provinces in the last eighteen months, verify that the CBSA exporter code on your CAD matches the entity CBSA has on file for preferential or reduced SIMA rates. A mismatch will trigger a verification request and potentially a full SIMA penalty if CBSA determines you under-declared duties knowingly.

HS classification and origin documentation

Most photovoltaic modules fall under HS 8541.43, but if your product includes inverters, mounting hardware, or battery storage integrated into a single shipped unit, the classification can shift. CBSA applies General Interpretative Rule 3 when multiple components are present, and the ruling can swing your duty rate and your SIMA exposure.

File at the wrong HS code and you’ll either overpay duties or underpay and face a correction notice. The AMPS penalty schedule starts at 5% of the duty shortfall for a first administrative error and scales up on repeat violations. If CBSA decides the misclassification was deliberate avoidance of the SIMA order, you’re into C-level penalties and possible referral for criminal prosecution under section 153 of the Customs Act.

We maintain a classification tool that walks through the decision tree for solar equipment, but if your product is anything other than a basic module, get a binding advance ruling from CBSA before you land the first shipment. The ruling request takes six to eight weeks, but it’s cheaper than a retroactive assessment on twelve months of entries.

Origin documentation is the second choke point. Even if your modules were assembled in Vietnam, Malaysia, or Thailand, CBSA may treat them as Chinese origin if the cells themselves were made in China and the substantial transformation test isn’t met. The CITT order applies to goods originating in China, not just goods shipped directly from Chinese ports, so a transshipment through Southeast Asia doesn’t automatically sidestep the SIMA duties.

Your supplier should provide a certificate of origin that breaks down the value-add by country. If they can’t, or if the certificate is generic boilerplate without factory-specific detail, assume CBSA will challenge it during a CUSMA or CPTPP origin verification. We’ve been through a dozen of these in the last two years and the ones that survive have itemized bills of material showing where each component was manufactured and the processing steps performed in the country of export.

Filing CADs under SIMA

When you file a CAD for subject goods, the SIMA code goes in the appropriate field, the Normal Value or export price goes into the valuation section, and the duty calculation runs automatically if your customs software is current. The catch is that CBSA expects you to know the exporter’s SIMA status before you file. If you’re using Release Prior to Payment and guessing at the duty rate to meet the release deadline, you’re gambling that your guess is within tolerance when CBSA runs the K84 reconciliation at month-end.

If the exporter is on CBSA’s list of cooperating parties with reduced margins, you need proof of that status in your file before you claim the reduction. CBSA publishes the exporter list on the CBSA SIMA page, but the list updates irregularly and lags behind CITT decisions by weeks. When in doubt, file at the all-others rate and request a refund later, because underpaying up front triggers an interest charge from the date of original accounting.

For importers filing monthly summaries under CARM, the SIMA duty calculation needs to match the amount CBSA shows on your release documentation. Discrepancies between the release amount and the final CAD will flag your account for audit, and once CBSA opens a verification file, they typically pull twelve months of history, not just the flagged transaction.

Coordination with sufferance and port-side release

Containers carrying solar modules into the Port of Montreal often sit in sufferance pending CBSA clearance, and if your shipment is flagged for SIMA verification, expect the hold to extend beyond the standard same-day or next-day release window. We coordinate cross-border freight through FENGYE LOGISTICS when port-side documentation and release timing matter, because a two-day delay in sufferance can cascade into missed delivery windows and additional drayage charges if your destination warehouse has tight receiving schedules.

If you’re filing PARS or using RMD for routine solar imports, make sure your broker has the SIMA documentation package in hand before the cargo control number is transmitted. CBSA won’t grant release prior to payment on subject goods without proof that the duty calculation is defensible, and if the release is delayed because your broker is waiting on supplier certificates, you’re paying the demurrage.

What to review before the next shipment

Pull your last six months of solar equipment entries and confirm that every CAD included the correct SIMA code, the correct exporter identifier, and a defensible origin certificate. If any entries were filed without those elements, calculate your duty exposure now and decide whether to file a voluntary correction before CBSA finds it during an audit.

Check your supplier contracts to make sure the party named as exporter on your commercial invoice matches the entity CBSA has on file for reduced SIMA rates. If your supplier changed legal names or restructured, you need an updated CBSA exporter confirmation letter before you file the next entry.

Review your RPP bond limit if you’re using release prior to payment for solar imports. SIMA duties can triple your per-shipment duty liability, and if your bond was sized for pre-SIMA import volumes, you may be under-secured. CBSA will suspend your RPP privileges if a single entry pushes you over 80% of your bond limit, and once that happens, every subsequent shipment clears on a transactional security deposit, which ties up working capital and delays release by 24 to 48 hours.

We run compliance audits for importers who want a second set of eyes on their SIMA files before CBSA asks. The ones who wait until the verification notice arrives are usually looking at six-figure duty corrections and a compressed timeline to respond. If your entries are clean, the audit confirms it. If they’re not, you have time to fix them before the penalty clock starts.

Get in touch if you need help reviewing your solar import program before the next container lands.

Source: CSCB