Recent industry checks in the United States suggest that an increase in US minimum import prices (MIPs) under the polysilicon Section 232 framework may not occur until after Dec. 4, with implementation potentially moving into early 2027.

The delay appears to reflect the Department of Commerce’s desire to observe how the initial Section 232 proclamation operates in practice. Commerce also appears to be seeking additional feedback from investors before adjusting the MIPs. For US solar manufacturers, a later increase would be an incremental negative that could delay intended pricing support for domestic production.

A central question is how the government will enforce the MIP, particularly when importers declare merchandise at that threshold. Under standard customs practice, most importers use the transaction value, which is the price actually paid or payable for the merchandise. The Section 232 framework does not, by itself, prevent an importer from using that method. If transaction value cannot be used, other established methods are available.

The more important issue is whether the declared value reflects the true economics of the transaction. Commerce and US Customs and Border Protection (CBP) are expected to scrutinize imports declared at the minimum price, including transactions involving companies without a history of importing at that level. Shipments may also be detained while Commerce or CBP verifies the underlying transaction. If the documentation does not support the declared value, authorities could take further action, potentially including the suspension of import licenses.

The administration appears prepared to take compliance seriously from the outset.

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