Section 201 safeguard tariffs on imported solar cells and modules expired in February 2026 after four years of layered duties on top of antidumping and countervailing rates. Installers who built quotes around “tariff adder” line items needed new language by spring — but homeowners comparing proposals still see confusing stacks: module pricing near $0.28/watt on some bids, FEOC (Foreign Entity of Concern) compliance premiums on others, and third-party lease structures absorbing credits the cash buyer no longer gets. Your quote is really three questions: what tariff regime applies, whether modules pass FEOC for the credit you need, and who owns the tax benefit.
What Section 201 Did — and What Ended
The Section 201 safeguard (2018–2026) added tariffs on crystalline silicon cells and modules beyond existing trade remedies. It pushed domestic assembly economics and kept imported module prices elevated during the IRA boom years.
Expiration removes that specific duty layer — not all trade barriers. Antidumping/CVD orders on specific countries, the Uyghur Forced Labor Prevention Act supply-chain scrutiny, and new investigations (including Section 232 on polysilicon derivatives) still move pricing. Think of February 2026 as closing one tab in the spreadsheet, not zeroing the trade column.
The U.S. International Trade Commission published the expiration schedule; installers should have stopped itemizing Section 201 as a separate pass-through after the cutoff unless holding pre-expiration inventory priced under old rules — ask for inventory date on quoted modules.
FEOC and §48E: The Bigger Price Driver Now
Direct homeowners lost the §25D residential credit for purchases starting 2025 unless safe-harbored. Third-party owners (lease/PPA providers) can still use §48E business credits if they meet ownership, beginning-of-construction, and FEOC compliance rules — including the July 4, 2026 safe-harbor deadline for certain equipment classifications.
FEOC rules restrict which module manufacturers qualify when the credit claimant needs full credit value. Non-compliant modules may install fine but break the financier’s tax equity model — showing up as higher lease rates or outright product restriction on TPO quotes.
When reading a 2026 quote:
- Cash/loan purchase: Focus on $/watt, inverter, warranty, installer viability — FEOC matters less for your tax position if you are not claiming §25D.
- Lease/PPA: Ask which module SKUs are FEOC-compliant and whether the safe-harbor timeline covers your install date.
- Compare apples: A cheaper module failing FEOC is not cheaper on a lease; a compliant module at $0.02/watt more may lower monthly payments.
Our lease vs. PPA 2026 framework walks ownership trade-offs.
Module Pricing Near $0.28/Watt — Context
Wholesale module prices dipped toward $0.28/watt on some Tier-1 bills of materials in mid-2026 as Section 201 expired and polysilicon softened — before any Section 232 polysilicon remedy lands. Retail quotes bundle labor, permitting, inverter, racking, margin, and finance fees; $2.50–$3.50/watt installed remains common depending on market and roof complexity.
If an installer still cites “Section 201 surcharge” after February 2026, request itemization against current Customs entries or switch comparables.
How to Read the Quote Line by Line
- Module make/model and wattage — lookup BloombergNEF or Pike tier; verify datasheet serial ranges.
- Tariff / trade compliance line — should reference active duties only; expired 201 should be gone.
- FEOC attestation — for TPO, written manufacturer compliance letter or installer indemnity language.
- Credit ownership — who claims §48E, and what happens if IRS disallows.
- Production guarantee vs. price — lower $/watt means little if degradation assumption is optimistic.
Cross-check our Southeast Asia import duties guide for overlapping remedies still in force.
Timing: Shop Now or Wait?
Section 232 polysilicon investigations could add upstream costs even for domestic assemblers — see our companion piece on polysilicon tariffs when published. Safe-harbor deadlines for §48E favor signed contracts with defined equipment if you are pursuing lease/PPA.
Waiting for “post-tariff crash” already partially happened at module level; labor and permitting inflation did not. If your roof and tree shade work today, quote three installers this month and compare normalized $/kWh year-one, not sticker wattage alone.
Section 201 expiration simplifies one footnote on the proposal. FEOC and third-party credit mechanics now dominate the fine print — read those lines before you sign.
