IEEPA Tariff Refunds on Solar Panels and Renewable Energy Equipment

Renewable energy equipment importers — particularly in the solar sector — faced some of the most complex tariff environments in recent trade history. Between Section 201 safeguard tariffs on solar cells, Section 301 tariffs on Chinese components, anti-dumping and countervailing duties on Chinese and Southeast Asian solar products, and IEEPA surcharges, the duty stack on a solar panel could exceed the panel’s FOB cost.

The Supreme Court’s February 2026 ruling in Learning Resources, Inc. v. Trump struck down IEEPA tariffs. The CIT’s March 4 order directed CBP to process refunds. For solar and renewable energy importers, the IEEPA recovery is significant — but only if you correctly distinguish which duties are recoverable and which are not.

This guide covers the critical distinctions and the recovery strategy. For the full process, see the complete guide to IEEPA tariff refunds.

Critical distinction: IEEPA vs. Section 201 safeguard tariffs

This is the most important concept for solar importers. Section 201 safeguard tariffs on solar cells and modules are NOT the same as IEEPA tariffs, and they are NOT refundable under the Supreme Court ruling.

Section 201 safeguard tariffs (NOT refundable)

Section 201 tariffs on crystalline silicon solar cells and modules were first imposed in January 2018 under the Trade Act of 1974. They apply to solar cells and modules from all countries (with limited exceptions) and were designed to protect the domestic solar manufacturing industry.

• Imposed under the Trade Act of 1974, Section 201
• Apply globally (not country-specific like IEEPA)
• Have been extended and modified multiple times
• Are not affected by the Supreme Court’s IEEPA ruling
• Are not refundable under the current recovery process

IEEPA surcharges (refundable)

IEEPA surcharges were a separate, additional layer imposed on top of Section 201 (and any other applicable duties) for products imported from covered countries. A Chinese solar panel imported during the IEEPA period might have carried:

Only the bottom row — the IEEPA surcharge ��� is recoverable. All other duty layers remain in effect.

For solar importers who sourced panels from Southeast Asia (Vietnam, Thailand, Cambodia, Malaysia) to avoid Chinese AD/CVD orders, those imports still faced IEEPA surcharges based on their country of origin. The IEEPA recovery applies to covered Southeast Asian origins as well.

Which renewable energy products qualify

Beyond solar panels, IEEPA surcharges applied to a wide range of renewable energy equipment from covered countries:

Solar sector

Solar cells. Mono-crystalline, polycrystalline, and thin-film cells imported for module assembly. These are typically classified under HTS 8541.40.

Solar modules/panels. Complete photovoltaic modules ready for installation. HTS 8541.40.

Inverters. String inverters, microinverters, and central inverters for solar installations. HTS 8504.40.

Mounting structures. Racking, trackers, and balance-of-system hardware. Various HTS chapters.

Solar glass. Specialty tempered glass for module manufacturing. HTS 7007.

Wind sector

Wind turbine components. Nacelles, blades, towers, and gearboxes imported from covered countries. These are high-value, heavy items with significant per-entry IEEPA exposure.

Wind tower sections. Steel tower sections are subject to both wind-specific AD/CVD orders (on certain origins) and IEEPA surcharges. Only the IEEPA component is recoverable.

Energy storage

Battery energy storage systems (BESS). Grid-scale and commercial battery systems. See also our lithium battery and EV components guide for detailed coverage of battery-specific considerations.

Other renewable equipment

Heat pumps. Air-source and ground-source heat pumps from covered countries.

LED lighting. Commercial and industrial LED fixtures and components.

Smart grid components. Transformers, switchgear, and grid management hardware from covered countries.

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The AD/CVD complexity in solar

The solar sector has the most complex AD/CVD overlay of any industry. Chinese solar cells and modules have been subject to anti-dumping and countervailing duties since 2012. Subsequent investigations extended AD/CVD coverage to solar products from Vietnam, Thailand, Cambodia, and Malaysia (the “circumvention” investigations).

This matters for IEEPA recovery because:

1. AD/CVD duties are not refundable. Only the IEEPA surcharge is recoverable. Your ES-003 report must be analyzed carefully to separate each duty layer.

2. Entries under AD/CVD administrative review may have suspended liquidation. If your solar entries haven’t been liquidated because they’re part of an ongoing AD/CVD review, they may still be eligible for PSC filing on the IEEPA component — which is the fastest recovery path.

3. Bonding requirements. Some solar importers posted bonds for estimated AD/CVD duties. The IEEPA recovery is separate from any AD/CVD deposit adjustments. Don’t confuse the two.

4. The “two-year exemption” period. In 2022-2024, certain Southeast Asian solar products received a temporary exemption from AD/CVD duties (the so-called “bridge” period). Products imported during this exemption window still faced IEEPA surcharges if they were from covered IEEPA countries. The IEEPA recovery applies regardless of the AD/CVD exemption status.

Calculating recovery for solar importers

Solar import recovery calculations require careful duty layer separation. Here’s an example:

Large-scale solar developer importing modules

Annual import volume: $30 million in solar modules from Vietnam

• MFN duty: $0 (most solar modules enter duty-free under MFN)
• Section 201 safeguard: $4,425,000 (14.75%)
• IEEPA surcharge (Vietnam): $13,800,000 (46%)
• Total duties during IEEPA period: $18,225,000
• Recoverable IEEPA component: $13,800,000

Solar installer importing inverters and racking

Annual import volume: $5 million in inverters from China, $3 million in racking from China

• IEEPA surcharge on inverters: $7,250,000 (145%)
• IEEPA surcharge on racking: $4,350,000 (145%)
• Total recoverable IEEPA: $11,600,000

Utility importing wind tower components

Annual import volume: $15 million in tower sections from Vietnam

• IEEPA surcharge: $6,900,000 (46%)
• Recoverable IEEPA: $6,900,000

The numbers are large because renewable energy equipment is capital-intensive and imported in significant volumes. The IEEPA surcharges on these products represented a meaningful addition to project costs.

Project economics and PPA implications

For solar and wind developers, IEEPA tariffs were incorporated into project financial models. The recovery has downstream implications:

Power Purchase Agreements (PPAs)

If you signed PPAs during the IEEPA period with pricing that reflected the tariff burden, the recovery changes the project economics retroactively. Review your PPAs for:

• Cost adjustment provisions tied to tariff changes
• Benefit-sharing clauses that require sharing cost savings with off-takers
• “Change in law” provisions that may be triggered by the Supreme Court ruling

Investment Tax Credit (ITC) basis

The ITC for solar projects is calculated on the cost basis of the project. If IEEPA duties were included in the cost basis, a refund may require a basis adjustment. This could reduce the ITC amount. Consult with your tax advisor immediately on the interaction between IEEPA recovery and ITC claims.

Production Tax Credit (PTC) projects

Wind and other PTC-eligible projects are less affected because the PTC is production-based, not cost-based. However, the IEEPA recovery still improves project IRR by reducing the effective capital cost.

Community solar and residential financing

For solar projects financed through tax equity partnerships, the IEEPA recovery may interact with partnership allocation provisions. Tax equity investors may have a claim on a portion of the recovery if the partnership agreement includes provisions for extraordinary receipts or cost adjustments.

Recovery paths for renewable energy importers

All four recovery paths are available:

PSCs for unliquidated entries. Solar and wind imports from mid-to-late 2025 may still be unliquidated, especially if they’re tied to AD/CVD administrative reviews. File PSCs immediately on these entries.

Protests for liquidated entries in the 180-day window. Project-based importers may have concentrated import activity around construction schedules, creating clusters of entries that approach the protest deadline together. Map every deadline.

CIT litigation for entries past the window. Given the high per-project values, CIT action is justified for virtually any renewable energy entry outside the protest window.

Immediate capital for developers with active project pipelines. Recovering IEEPA duties as immediate cash can fund current project development without additional project finance borrowing. The treasury cash flow analysis framework applies directly to project finance capital planning.

Forward-looking considerations

Policy stability

Renewable energy trade policy has been among the most volatile areas of U.S. trade law. Between Section 201 extensions, AD/CVD investigations on Southeast Asian panels, IEEPA surcharges, and Section 301 rate increases, the tariff landscape has shifted repeatedly. The IEEPA ruling removes one layer, but the others remain.

Domestic manufacturing impact

The combination of IRA incentives and tariff protection has driven significant investment in domestic solar manufacturing. The IEEPA recovery doesn’t change the IRA incentive structure, but it does reduce the tariff deterrent for importing. Monitor how this affects domestic module pricing and availability.

Project pipeline planning

For projects currently in development, incorporate the post-IEEPA duty structure into your financial models. The effective import cost of solar equipment from covered countries has decreased by the IEEPA surcharge amount. This improves project economics and may make previously marginal projects viable.

The installer and EPC perspective

Solar installers and EPC (engineering, procurement, construction) companies are often the importers of record for solar equipment. Their IEEPA recovery has project-level implications:

Project margin restoration. Installers who bid projects before IEEPA tariffs were imposed, then had to import equipment at tariff-inflated prices, suffered margin compression. The IEEPA recovery retroactively improves those project margins. For companies that lost money on IEEPA-period projects, the recovery can turn unprofitable projects positive.

Bid strategy adjustment. Going forward, EPC companies should remove the IEEPA surcharge from their cost estimates for future bids. The tariff is gone, and the recovery is underway. Continuing to include it in bids inflates pricing unnecessarily and reduces competitiveness.

Bonded project implications. For projects with performance bonds, the IEEPA recovery may affect the bond calculation if the bonded amount was based on project cost including tariff-inflated equipment prices. Notify your surety company.

Multi-project portfolio. Large EPC firms with multiple solar projects from the IEEPA period need to track recovery proceeds by project. This requires matching customs entries to specific project purchase orders — a data integration task that the operations manager’s guide addresses.

Bifacial module and technology-specific considerations

Certain solar technologies had unique tariff treatment during the IEEPA period:

Bifacial modules. Bifacial solar modules received temporary exemptions from Section 201 safeguard tariffs at various points, but the IEEPA surcharge applied regardless of bifacial exemptions. If your bifacial module entries have IEEPA surcharges, they’re recoverable even though the modules may have been exempt from Section 201.

Thin-film technology. CdTe (cadmium telluride) and CIGS thin-film modules have different HTS classifications than crystalline silicon modules. Verify that the IEEPA surcharge was correctly assessed on thin-film entries — some classifications may have been treated differently.

Module-level power electronics (MLPEs). Microinverters and DC optimizers are separate from the module and have their own HTS classifications. If imported separately, each has its own entry and its own IEEPA recovery calculation.

Trackers and racking. Mounting systems are classified separately from modules. Steel-based racking systems may also be subject to Section 232 tariffs on steel — separate IEEPA from Section 232 on these entries.

Community solar and distributed generation

The community solar market expanded significantly during the IEEPA period despite tariff headwinds. Community solar developers importing equipment for multi-site portfolios may have substantial aggregate IEEPA claims even if individual project claims are moderate.

Portfolio-level filing. If you developed 20 community solar projects during the IEEPA period, each with $500,000 in imported equipment subject to IEEPA surcharges, the aggregate recovery across the portfolio could exceed $2-3 million. File on all entries, not just the largest projects.

Subscriber pricing implications. Community solar subscribers often pay based on the project’s cost structure. If the IEEPA recovery reduces the effective project cost, subscriber pricing may be subject to adjustment under the subscription agreement or state regulatory requirements.

Action plan

1. Separate IEEPA from Section 201, AD/CVD, and Section 301. This is non-negotiable. Only IEEPA is recoverable.

2. Check for entries in AD/CVD administrative review. These may have suspended liquidation, creating PSC opportunities.

3. Review PPA and financing agreements. Identify any cost adjustment or benefit-sharing provisions that may be triggered.

4. Consult on ITC basis. Determine whether the IEEPA refund requires an ITC basis adjustment.

5. Request an Impact Assessment. The entry-level analysis separates every duty layer and maps each entry to the optimal recovery path.

Heat pump and energy efficiency equipment

The broader renewable energy and energy efficiency sector includes heat pumps and related equipment that were subject to IEEPA surcharges:

Air-source heat pumps. Imported from China, Japan, and South Korea, these units faced significant IEEPA surcharges. The IRA provided consumer tax credits for heat pump installation, which drove increased demand — and increased import volumes subject to IEEPA tariffs.

Ground-source (geothermal) heat pumps. Components for ground-source systems imported from covered countries.

Variable refrigerant flow (VRF) systems. Commercial HVAC systems from Asian manufacturers. These are high-value imports with substantial per-unit IEEPA exposure.

Heat pump water heaters. Imported from China and other covered countries. Another product category where IRA incentives drove increased demand during the IEEPA period.

The interaction between IRA clean energy tax credits (which incentivized purchase) and IEEPA tariffs (which penalized import) created a particularly frustrating dynamic for installers and distributors. The recovery resolves the tariff side of that equation.

Offshore wind components

The emerging U.S. offshore wind industry imports major components from covered countries:

Monopiles and foundations. Large steel structures imported from European fabricators. These are extremely high-value per-entry items — a single monopile foundation can cost several million dollars.

Nacelles and drivetrains. Assembled in European factories and shipped to U.S. project sites. The IEEPA surcharge on a single nacelle can exceed $500,000.

Subsea cables. Power export cables and array cables manufactured in Europe and Asia. These specialty products have limited global sourcing options.

Installation vessels. While vessels themselves aren’t typically “imported” for duty purposes (they’re admitted temporarily), vessel components and equipment imported for installation support were subject to IEEPA surcharges.

Offshore wind projects represent some of the largest capital investments in the energy sector. The IEEPA recovery on imported components for a single offshore wind project can total tens of millions of dollars.

The renewable energy sector’s IEEPA recovery is complicated by overlapping trade remedies, project finance structures, and tax credit interactions. Getting the analysis right is essential.

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