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China's Solar Exports: the Rise of a Photovoltaic Powerhouse

2020-08-26 Voice Announcements

Over the last twenty years, power has increasingly come from photovoltaic (PV) solar energy systems. A recent documentary, Planet of the Humans, attacks several elements of industrial PV systems, such as their overall life cycle and supposed dependency on fossil fuel components. This article examines the critical components in the construction of solar energy. It then looks at the major players in photovoltaic manufacturing. It then focuses on the disputes that the US and EU have raised against China's expansive subsidies for photovoltaics. The article concludes that Chinese subsidies were extensive, but justifiable given the global public benefit of affordable renewable power and energy.

Many homeowners and some businesses install their own solar energy panel systems. But the majority of homeowners and businesses still rely on the grid. This article focuses on grid-based solar power farms.

I. The Critical Components of Photovoltaic Power

We can divide photovoltaic technology into three broad categories: panels, batteries, and the connectors (charge regulators and DC-to-AC inverters). Note that solar racking, wiring, ground mounts, and other structural aspects of the arrays and systems serve as supportive roles to the active components of photovoltaic power.

Panels

When we think of solar power, the mind's eye draws itself to the iconic photovoltaic panel. After all, the panels collect sunlight as energy. Often composed of crystals, solar panels range from about 18%-22% conversion efficiency, although even five-year old panels may operate with significantly less efficiency.[1]

Panels combine ingots, wafers, and cells to form modules within a PV array to process sunlight. Panels employ crystals. Crystalline silicon has become the dominant semiconductor. As of 2017, c-Si accounted for as much as 96% of production.[2]

Batteries

The development of battery capacity and technology charts the story of photovoltaic power from promise to reality. Batteries, of course, store and provide power as the sun's radiance dims. They balance photovoltaic output variance. Battery materials can include lead-acid, nickel-cadmium, nickel hydride, and trusty lithium. Modern batteries must withstand deep charging and discharging cycles without too much degradation. The film Planet of the Humans claims photovoltaic batteries remain too primitive to support reliance on solar, however, this fails to capture the potential of battery technology as of 2020.

Connectors

Charge regulators handle voltage conversion and maximum power tracking.[3] They protect batteries from damage and prevent either overcharge or excessive discharge of energy. [4]

The electrical grid runs on AC power. So DC to AC inverters convert the DC power the solar modules emit into compatible AC power. The typical efficiency of an inverter well matched to the array is around 90%. Unfortunately, the inverters produce electromagnetic noise, and occasionally interfere with sound and video equipment. Photovoltaic to grid interconnection chiefly concerns power quality and safety. That includes the inverter's ability to shut down power to the gird should the grid come offline unexpectedly.

Where are Photovoltaic Components Manufactured？

The world sources much of its components from the Mainland China and Taiwan. Mainland China and Taiwan dominate ingot/wafer, cell, and module manufacturing as a share of global production. It supplies over three-fourths of the globe's ingot/wafers and cells, and well over a majority of the world's modules.[5] Greater China's influence over photovoltaics was felt in April 2020 when the entire solar pipeline suffered from major hiccups as China factories shut down for the Coronavirus. "The effect of the virus on global renewables markets could make 2020 the first 'down year' for solar power capacity addition since the 1980s, according to BloombergNEF."[6] United States based tax rebates also expired in 2020, but growth in this sector may rebound in 2021 and return to its long-term bullish trajectory.[7]

Prices for PV components exhibit substantial volatility, but the overall trend has witnessed a significant overall drop in prices for components. Modern components assembled into an active system would collectively possess a 20-30 year life span, contra Planet of the Humans' depiction of far briefer life cycles.

II. Who are the big players in solar energy construction？

Chinese companies stand foremost within the photovoltaics field: Jinko Solar, JA Solar, Trina Solar, LONGi Solar, Risen Energy, Talesun, GCL-SI. North America features Canadian Solar and First Solar. Hanwha Q Cells remains a powerful South Korean player in photovoltaics with a significant footprint in Germany. We discuss a few of the mainland Chinese companies below.[8]

Jinko Solar began as a wafer supplier and expanded towards comprehensive photovoltaics supply by 2012. Jinko's revenues for 2019 summed to nearly RMB 30 billion, or USD 4.27 billion. The global PV supplier demonstrated manifest confidence in its rebound from COVID-related slowdowns when it announced a USD 100 million share buyback program in March, 2020. Jinko Solar seems to be the largest and most prominent solar PV component manufacturer in the world.

JA Solar, based in Beijing, sells solar modules and cells to customers in Europe and North America. After the U.S. pledged to leave the Paris Accords, JA Solar's Li Tao proclaimed, “China has an opportunity to surpass Western countries in new energy." JA Solar has seized that opportunity and partnered with Manitu Solar to expand towards the western end of the Belt and Road and into Eastern Europe's markets.[9]

LONGi Solar became the largest PV module manufacturer last year. Its major production facility is in Anhui, China. Recently, LONGi Green Energy Technology constructed another manufacturing facility Kuching City, Sarawak, Malaysia from which LONGi Solar can produce 1GW of solar cells.[10]

Trina Solar is world-renowned for balancing cutting-edge research and development alongside rapid commercial integration and implementation. It privatized and delisted from the New York Stock Exchange in 2017, deciding to do so at about the same time it set a mono PERC cell efficiency record of 22.61% solar ray to energy conversion ratio. In 2017, Trina Solar's landmark research and development team hit a new record of over 24% conversion with one of its IBC cells. Just last year, Trina Solar achieved 24.58% for a cell based on n-type monocrystalline TOPCon technology.[11]

Mainland China is without peer when it comes to solar PV manufacturing. In terms of output and revenue, together Jinko Solar, JA Solar, LONGi Solar, and Trina Solar match their competitors from the rest of the industrialized world.

III. Cloudy Days Behind, Sunny Days Ahead: The Wax and Wane of Chinese Solar Subsidies and EU- and US-Disputes

Major nations advanced subsidies for solar production and distribution. Both China and the United States, for example, have implemented major subsidies or incentives for solar purchase and production. China's industry subsidies have bolstered the manufacturing and development of its, really now the world's, photovoltaics components.

It would be misleading to credit too much of China's dominance of photovoltaic production to its generous subsidies. Nonetheless, those subsidies are what have attracted disputes aimed at China's solar miracle. [12]

The first Chinese solar subsidies came online in 2009. The Golden Sun program offered at least 50 percent of investment for solar power projects, but as much as 70 percent for regions with no other power supply, subject to certain requirements and minimum project output.[13] China introduced a Feed-In Tariff in 2011. This awarded at least 15 cents per kilowatt-hour to photovoltaics firms which sold electricity to utilities.[14]

These two policies together primarily aimed at stimulating China's domestic demand. But an array of formal and local subsidies for photovoltaic manufacturing pushed China from a non-player in 2005 to a leading exporter within seven years. Subsidies included "low-cost loans, tax rebates, research grants, cheap land, energy subsidies and technological, infrastructure and personnel support."[15] More than simply cheap capital, China's local governments served as land banks to issue bottom-of-the-barrel land lease terms to potential PV manufacturing plants.[16] Major solar panel manufacturers Wuxi Suntech and Shanghai Chaori received bailouts.[17] China had already set bold targets in its 2005 Renewable Energy law, but the economic downturn provided a real push for further government intervention.

US Pressure on China

United States pressure on Chinese solar photovoltaic imports has been unrelenting. Initiated in 2012, the barriers lingered, and saw significant expansion in 2017 and 2018. The Commerce Department slapped tariffs as early as 2012 due to Chinese government subsidies. Trump's tariffs under Section 301 and 201 made modules from China substantially less cost-effective, sending ripples of pain throughout the US domestic photovoltaic industry.

In 2011, the United States was gripped by the Solyndra saga. The US Department of Energy guaranteed the solar and photovoltaic start-up a $535 million loan through the Energy Policy Act of 2005 and the subsequent American Recovery and Reinvestment Act of 2009. Solyndra defaulted on the loan in 2011. The Republican Party, buoyed by fossil fuel contributions, bally-hoo'd the failure as an emblem of the ARRA's waste and the failure of US government subsidies for green energy more generally. Nonetheless, Former Energy Secretary Ernest Moniz assured NPR that the Energy Policy Act, the ARRA, and the US Department of Energy loan guarantees "literally kick-started the whole utility-scale photovoltaic industry." Solar and photovoltaics in the United States had emerged as a public-private partnership.[18]

Unfortunately, Solyndra was not the only US PV company feeling pressure. Silicon solar PV panels dropped 50% in price in the year 2011. SolarWorld Industries America shuttered a California manufacturing facility.

A collision arose between the photovoltaic industrial policies of China and the United States. US PV companies reached for anti-dumping and protectionist tools in the national arsenal. The United States had to show subsidies have been paid and caused actual harm to domestic industry under the GATT-WTO regime to erect anti-dumping penalties, or under pre-existing US law, at a minimum it must show the threat of serious injury to US industries from foreign state subsidies under Section 201 of the 1974 Trade Act. China resisted, and US PV companies had to overcome federal judicial interpretation of statute, and a subsequent adverse WTO ruling. Congress and President Barack Obama disposed of each when the latter signed Congress's statute into law in March 2012. It stated: "the merchandise on which countervailing duties shall be imposed ... includes ... merchandise imported ... into the USA from a nonmarket economy country."[19]

In May 2012, the US Commerce Department levied a preliminary duty with a margin of a fraction over 31% on the basis of $3.1 billion in Chinese photovoltaic imports the previous year. At the conclusion of its Section 201 (of the 1974 Trade Act) investigation on October 2012, the US Commerce Department assessed that Chinese producers had been in receipt of subsidies worth 14.78 to 15.97 percent which were capable of counteraction. The ITC unanimously approved and upheld the tariffs the next month on the grounds that the Chinese subsidies materially threatened the US solar industry.[20]

The anti-dumping duties amounted to something less than a comprehensive counter to the full panoply of subsidies available, but the 14-16% were the "countervailable" figure for subsidies. After all, the US Commerce Department assessed that outside of several dozen exporters, the remainder of Chinese exporters had received a final dumping rate of 249.96 percent. Certainly, the Chinese subsidies lowered the costs of photovoltaics; crystalline silicon modules dropped 30% and thin film prices decreased by 20%. Unfortunately, China's domestic FIT had yet to kick in, and as of 2015, Chinese domestic photovoltaic demand had not realized its full potential.[21]

The Coalition for Affordable Solar Energy, 700 members from companies involved in photovoltaic and solar innovation, engineering, and production, came out strongly against the US's anti-dumping actions. It complained that ITC hearings offered no standing to downstream users of any photovoltaic product. For PV energy plants, China's subsidies would save conceivably every American money on their power utility bill.[22]And the savings were for green, renewable power, which are themselves forced to compete with substantial fossil fuel subsidies. One estimate places fossil fuel subsidies at $20 billion per year (figure includes indirect subsidies). The benefits to America from China's photovoltaic push are broad, and long-lasting. China's "dumping" serves as a small push for the entire planet to liberate itself from dependency on carbon emissions.[23]

Therefore, the industrial policies of the United States and China have contributed to a maturing and increasingly self-reliant and efficient private sector in the United States. However, further clashes over China's photovoltaic subsidies would emerge following Donald Trump's election and the initiation of his so-called Trade War.

Suniva kicked off the petition to the ITC in May 2017, as is necessary for Section 201 tariffs (from the 1974 Trade Act), and SolarWorld quickly joined it. The process, which included a December public hearing, concluded in January 2018. The Section 201 tariffs set a rate of 30% duties on solar cells and modules that would decrease 5% annually until it reached 15% on the fourth year. Thus, solar panels (and washing machines) were to become the initial tariffs levied in the supposed "Trade War." The Section 201 solar cell and inverter tariffs applied against China, Japan, South Korea, indeed even Canada and all other countries except for certain qualifying developing countries (depending on coming within individual or collective thresholds on total import values).[24]

Bifacial solar panels received an exemption from the Section 201 tariffs in June 2019. These exemptions were rescinded in May 2020 after a USTR notice determined the exemptions may likely have been holding back domestic production and innovation.[25]

However, the Trump administration moved beyond the aforementioned Section 201 tariffs and looked to Section 301 of the same 1974 Trade Act, and Section 232 of the Trade Expansion Act of 1962. Section 232 may trigger when the quantities of goods, or the circumstances of their import, implicate national security according to findings through the US Department of Commerce. Section 301 comes into play whenever the President directs the US Trade Representative to investigate whether, and the USTR so determines, that the rights of the US under a trade agreement have been denied, whether it is unjustifiable and burdensome or should it either violate or be inconsistent with the provisions of a trade agreement.[26]

The United States determined that Section 232 tariffs would be applied on steel and aluminum across the world, at rates of 25% and 10% respectively. These do not commonly impact critical components of photovoltaic solar power in a direct manner; they may, however, increase prices for some of the supportive structures and can increase construction costs overall across the entire photovoltaic superstructure.

The Trump administration leveled Section 301 penalties on China specifically. USTR did so after two public comment periods and an October 10, 2017 public hearing. In 2018, the US finally slapped 25% import tariffs on solar modules, cells, and inverters.[27]

At least 98% of photovoltaic and solar components used in US construction are manufactured outside of the US. Right now, imported solar modules and other components can exceed 40% the cost of those sold in similar markets, such as Australia or Europe. According to Xiaojing Sun at Wood MacKenzie Power and Renewables, "The general consensus is, were there no tariffs, there would probably be more solar."[28]

Unfortunately, the Trump administration may well support photovoltaic protectionism in part to slow the photovoltaic industry, and as a favor to fossil fuel interests. Early indications suggest that the Biden administration would pivot to target products with a higher carbon footprint with tariffs and may rollback tariffs on photovoltaics. In either case, Chinese solar producers may expect tariff barriers from the United States for years to come, even as the Chinese government winds down its photovoltaic subsidies.

The Conclusion of EU Tariffs on China and China's Phase-Out of Subsidies

European Union pressure on Chinese photovoltaic manufacturing and supply has largely receded into the rear-view mirror. In 2013, the EU Commission set anti-dumping and penalties on panels, wafers, and cells due to Chinese subsidies. The Commission concluded the tariffs in September 2018. However, EU prosecutions of smugglers and evaders of the tariffs have arisen since. Nonetheless, the conclusion of the EU's solar tariffs offer lessons for the US cooperation with China on solar may offer substantial reward.

The EU did not stand silent in the face of China's significant industry policies in favor of photovoltaic production. The European Commission decided to slap duties on China as “an amicable solution" to what it characterized as a looming "trade war."[29] The European Commission ended those punitive measures on September 3, 2018.[30]

Closing the conflict resulted in a boom for solar construction. "In the European Union, the abolition of the MIP created a virtual solar renaissance, with solar installations in the EU forecast to grow by as much as 80% year-on-year in 2019, after the MIP was rescinded last September." However, the EU seems to remain dependent upon foreign manufacturing for photovoltaics and batteries.[31]

The EU's climb-down coincided with China's phase-out of subsidies. In December 2017, and again on May 31, 2018, Beijing slashed feed-in-tariff subsidies dramatically. Guided electricity price subsidies for solar plummeted to 0.50, 0.60, and 0.70 yuan, down originally from 0.90, 0.95, and 1.00 yuan respectively. Distributed solar installations dropped from 0.42 yuan per kilowatt hour to just 0.32 yuan. However, feed-in-tariffs for poverty alleviation PV projects at the local level were kept static.[32]

In April 2020, Beijing set subsidies of 1 billion RMB for photovoltaic projects (distributed and utility), as total subsidies saw a 50% reduction. The Chinese government has announced plans to eliminate all feed-in tariffs and subsidies for solar PV, even in the distributed generation segment, starting from 2021.[33]

IV. A Bright Future for Photovoltaic Power

The 21st Century's Factory for the World has directed a substantial amount of resources towards the development of photovoltaic power. The United States has construed this as a threat to its photovoltaics industry, and even the EU once had put in place offsets for Chinese subsidies. But China's subsidies appear defensible as long as we keep our focus on the greatest of challenges: how do we, as a world, transition from an overreliance on fossil fuels towards a sustainable energy power source.

China has now established manufacturing expertise in the field of photovoltaics, its power symbolized in Jinko Solar, JA Solar, Trina Solar, and LONGi Solar. China has begun easing off the subsidies, and pledges to remove the support for photovoltaics in 2021. Will the United States respond and remove tariffs? Or will it deem the support already offered to Chinese photovoltaics as a legacy which requires re-balancing? Our ever-warming world still suffers from the legacy of two hundred years of fossil fuel emissions from the United States. A dozen years of Chinese subsidies to lower the price of solar photovoltaics appears quite reasonable, particularly aside existing fossil fuel subsidies. The benefit to the world public could prove incalculable. Admittedly, Chinese photovoltaics manufacturing also now holds the prize, too, a position of sophistication and market dominance from which Chinese talent and know-how can develop cutting-edge competitive photovoltaic technology for the future.

Of course, the US and EU may have preferred to see a domestic manufacturing base develop robust enough to match their demand for photovoltaic power. But as David Mooney reminds us, 250,000 American jobs in the solar panel assembly, installation, and maintenance business cannot be outsourced.[34]

As the passage of Sino-American commercial relations and cooperation undergoes renewed scrutiny, we should stop and reflect on how the rising power of photovoltaics had to challenge the legacy of fossil fuels. Perhaps this could not have been accomplished without the backing of full-bore industrial policy from a leading nation-state. As affordable photovoltaic power begins to spread across Europe and North America, and increasingly also the rest of the world, let us not withhold credit from China. For if our world becomes solar powered, this will be as much the achievement of Chinese power and innovation as that of any other country on the globe.

[注]

[1] Maddle Stone, Solar panels are more efficient than you’ve heard. This material could make them even better, Grist (May 13, 2020), https://grist.org/energy/solar-panels-are-more-efficient-than-youve-heard-this-material-could-make-them-even-better/

[2] Michael Woodhouse et al., Crystalline Silicon Photovoltaic Module Manufacturing Costs and Sustainable Pricing: 1H 2018 Benchmark and Cost Reduction Road Map (NREL Feb. 2019). https://www.nrel.gov/docs/fy19osti/72134.pdf

[3] [Kalogirou, 2009].

[4] Mark Fedkin, Main Components of Large PV Systems, PSU, https://www.e-education.psu.edu/eme812/node/681 (last visited Aug. 13, 2020).

[5] Michael Woodhouse, Supra. at 13

[6] James Murray, Coronavirus disrupting global solar PV supply chains, says analyst, NS Energy Business (Apr 8, 2020), https://www.nsenergybusiness.com/news/coronavirus-solar-pv/。

[7] Nichola Groom, Expiring U.S. solar subsidy spurs rush for panels, Reuters (July 19, 2019), https://www.reuters.com/article/us-usa-solar-subsidy-focus/expiring-u-s-solar-subsidy-spurs-rush-for-panels-idUSKCN1UE0CO

[8] Top 10 Solar Energy Companies in the World 2019, Technavio Blog (May 9, 2020), https://blog.technavio.com/blog/top-10-solar-energy-companies

[9]Keith Bradsher, China Looks to Capitalize on Clean Energy as U.S. Retreats, N.Y. Times, June 5, 2017, https://www.nytimes.com/2017/06/05/business/energy-environment/china-clean-energy-coal-pollution.html

BRIEF-JA Solar Partners With Manitu Solar To Expand In Eastern European Markets, Reuters (Feb. 2, 2018), https://www.reuters.com/article/brief-ja-solar-partners-with-manitu-sola/brief-ja-solar-partners-with-manitu-solar-to-expand-in-eastern-european-markets-idUSFWN1PR1D3

[10] Mark Osborne, LONGi Solar becomes world’s largest module manufacturer with latest expansion, PV-Tech (Mar. 11, 2019), https://www.pv-tech.org/news/longi-solar-becomes-worlds-largest-module-manufacturer-with-latest-expansio

Mark Osborne, LONGi to build new 1GW mono solar cell plant in Malaysia, PV-Tech (Feb. 25, 2019), https://www.pv-tech.org/news/longi-to-build-new-1gw-mono-solar-cell-plant-in-malaysia

[11] Mark Hutchins & Vincent Shaw, New cell efficiency records for Trina and Canadian Solar, PV Magazine (May 28, 2019), https://www.pv-magazine.com/2019/05/28/trina-lays-claim-to-a-bifacial-mono-i-topcon-record/

Tom Kenning, Trina sets new mono PERC cell efficiency record of 22.61%, PV-Tech (Dec 19, 2016), https://www.pv-tech.org/news/trina-sets-new-mono-perc-cell-efficiency-record-of-22.61

Mark Osborne, Trina Solar achieves 24.13% conversion efficiency for IBC solar cell, PV-Tech (May 5, 2017), https://www.pv-tech.org/news/trina-solar-achieves-24.13-conversion-efficiency-for-ibc-solar-cell

Mark Hutchins & Vincent Shaw, supra.

[12] Nichola Groom, supra. John Fialka & ClimateWire, Why China Is Dominating the Solar Industry, Scientific American (Dec. 19, 2016), https://www.scientificamerican.com/article/why-china-is-dominating-the-solar-industry/

[13] See July 16, 2009: 《财政部科技部国家能源局关于实施金太阳示范工程的通知》（财建〔2009〕397号）The Ministry of Finance, Ministry of Science, & National Energy Bureau, the Notice of the Implementation of Golden Sun Demonstration Projects (Cai Jian 2009, No. 397), https://sites.google.com/site/chinapolicyinfocus/china-s-solar-subsidy-programs/china-s-solar-industry/china-s-national-solar-subsidy-programs

[14] Coco Liu & ClimateWare China Uses Feed-In Tariff to Build Domestic Solar Market,, N.Y. Time (Sep. 14, 2011), https://archive.nytimes.com/www.nytimes.com/cwire/2011/09/14/14climatewire-china-uses-feed-in-tariff-to-build-domestic-25559.html

[15] Chen Gong, China's Solar PV Manufacturing and Subsidies from the Perspective of State Capitalism, The Copenhagen Journal of Asian Studies 33(1) p. 97, 2015

[16] Id. at 98.

[17] Id. at 100.

[18] Jeff Brady, After Solyndra Loss, U.S. Energy Loan Program Turning A Profit, National Public Radio (Nov. 13, 2014), https://www.npr.org/2014/11/13/363572151/after-solyndra-loss-u-s-energy-loan-program-turning-a-profit

[19] David P. Vincent, The Global Cost of Green: Recent Trade Issues and Litigation between the United States and China May Dissolve Global Green Cooperation, 39 Wm. & Mary Envtl. L. & Pol'y Rev. 141 (2014). https://scholarship.law.wm.edu/wmelpr/vol39/iss1/5

Sungjoon Cho, Thomas H. Lee, Double Remedies in Double Courts, European Journal of International Law, Volume 26, Issue 2, May 2015, Pages 519–535, https://doi.org/10.1093/ejil/chv026

See also GPX Int'l Tire Corp. v. United States, 645 F. Supp. 2d 1231, 1241 n.9 (Ct. Int’l Trade 2009); Act of March 13, 2012, Pub. L. No. 112–199, 126 Stat. 265.

[20] Commerce Preliminarily Finds Dumping of Crystalline Silicon Photovoltaic Cells, Whether or Not Assembled into Modules from the People’s Republic of China, U.S. DEP'T OF COMMERCE, INT'L TRADE ADMIN. 1 (October 10, 2012), available at https://enforcement.trade.gov/download/factsheets/factsheet-prc-solar-cells-ad-prelim-20120517.pdf

Keith Bradsher & Diane Cardwell, U.S. Slaps High Tariffs on Chinese Solar Panels, N.Y. Time (May 17, 2012), https://www.nytimes.com/2012/05/18/business/energy-environment/us-slaps-tariffs-on-chinese-solar-panels.html

Commerce Finds Dumping and Subsidization of Crystalline Silicon Photovoltaic Cells, Whether or Not Assembled into Modules from the People's Republic of China, U.S. DEP'T OF COMMERCE, INT'L TRADE ADMIN. 1 (October 10, 2012), available at https://enforcement.trade.gov/download/factsheets/factsheet_prc-solar-cells-ad-cvd-finals-20121010.pdf.

US panel affirms tariffs on Chinese solar products. BBC News (Nov. 8, 2012), https://www.bbc.com/news/business-20247734

[21] Chen Gong, China's Solar PV Manufacturing and Subsidies from the Perspective of State Capitalism, The Copenhagen Journal of Asian Studies 33(1) p. 97, 2015

[22] Gary Clyde Hufbauer & Martin Vieiro, US Anti-Dumping Duties on Chinese Solar Cells: A Costly Step, Peterson Institute for International Economics (May 25, 2012), https://www.piie.com/blogs/realtime-economic-issues-watch/us-anti-dumping-duties-chinese-solar-cells-costly-step

[23] Clayton Coleman & Emma Dietz, Fact Sheet: Fossil Fuel Subsidies: A Closer Look at Tax Breaks and Societal Costs, Environment and Energy Study Institute (July 29, 2019), https://www.eesi.org/papers/view/fact-sheet-fossil-fuel-subsidies-a-closer-look-at-tax-breaks-and-societal-costs。

[24] Office of the U.S. Trade Representative, Fact Sheet, Section 201 Cases: Imported Large Residential Washing Machines and Imported Solar Cells and Modules, https://ustr.gov/sites/default/files/files/Press/fs/201%20Cases%20Fact%20Sheet.pdf (last visit Aug. 13, 2020)

The weekend read: The specter of PV protectionism, PV Magazine (Sep. 21, 2019), https://www.pv-magazine.com/2019/09/21/the-weekend-read-the-specter-of-pv-protectionism/

[25] PV InfoLink, Bifacial modules lose exemption from Section 201 tariffs, again, InfoLink (Apr. 29, 2020), https://www.infolink-group.com/en/solar/analysis-trade-wars/Bifacial-modules-loses-exemption-from-Section-201-tariffs-again

Determination on the Exclusion of Bifacial Solar Panels From the Safeguard Measure on Solar Products, 85, Fed. Reg. 21497 (Off. of the U.S. Trade Rep. Apr. 17, 2020). https://www.federalregister.gov/documents/2020/04/17/2020-08189/determination-on-the-exclusion-of-bifacial-solar-panels-from-the-safeguard-measure-on-solar-products

[26] BROCK R. WILLIAMS ET AL., CONG. RESEARCH SERV., R45529, TRUMP ADMINISTRATION TARIFF ACTIONS (SECTIONS 201, 232, AND 301): FREQUENTLY ASKED QUESTIONS 9 (2019), https://perma.cc/UY5C-2CU8

[27] Office of the U.S. Trade Representative, Fact Sheet, Section 301 Investigation Fact Sheet (June 2018), https://ustr.gov/about-us/policy-offices/press-office/fact-sheets/2018/june/section-301-investigation-fact-sheet

[28] Emma Foehringer Merchant, WoodMac: Lifting US Import Tariffs Would Knock 30 Percent Off Solar System Prices, Greentech Media (Feb. 4, 2020), https://www.greentechmedia.com/articles/read/WoodMac-Lifting-US-Solar-Import-Tariffs

Michaela D. Platzer, Domestic Solar Manufacturing and New U.S. Tariffs, Congressional Reseacher Service (Feb, 2, 2018) https://fas.org/sgp/crs/misc/IF10819.pdf

[29] Agence France-Presse, EU lifts five-year-old restrictions on solar panels from China, South China Morning Post (Sep. 4, 2018), https://www.scmp.com/news/china/article/2162599/eu-lifts-five-year-old-restrictions-solar-panels-china

[30] Philip Blenkinsop, EU ends trade controls on Chinese solar panels, Reuters (Aug. 31, 2018), https://www.reuters.com/article/us-eu-china-trade/eu-ends-trade-controls-on-chinese-solar-panels-idUSKCN1LG1QM

[31] The weekend read: The specter of PV protectionism, PV Magazine (Sep. 21, 2019), https://www.pv-magazine.com/2019/09/21/the-weekend-read-the-specter-of-pv-protectionism/

[32] Liu Bin, China solar industry struggles through sudden subsidy cuts, Climate Home News (Aug. 15, 2018), https://www.climatechangenews.com/2018/08/15/china-solar-industry-struggles-sudden-subsidy-cuts/

Towards a subsidy-free era for China’s solar PV market, Apricum (Nov. 19, 2019), https://www.apricum-group.com/towards-a-subsidy-free-era-for-chinas-solar-pv-market/

[33] Vincent Shaw, China finalizes 2020 solar subsidy policy, PV Magazine (Apr. 9, 2020), https://www.pv-magazine.com/2020/04/09/china-finalizes-2020-solar-subsidy-policy/

Emiliano Bellini, China entering post-FIT era with solid prospects, PV Magazine (June 17, 2020), https://www.pv-magazine.com/2020/06/17/china-entering-post-fit-era-with-solid-prospects/

[34] John Fialka, supra.

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China's Solar Exports: the Rise of a Photovoltaic Powerhouse