Canada Market Access · Trade Policy Update
Last reviewed: September 20, 2026 · Written for Canadian buyers, not for exporters
The short answer: On September 17, 2026, the Canadian International Trade Tribunal (CITT) terminated expiry review RR-2020-001 and rescinded the order behind Canada’s anti-dumping and countervailing duties on certain Chinese photovoltaic modules and laminates. The Canada Border Services Agency (CBSA) will not continue to impose those duties on the covered goods.
This is a trade-remedy reset. It is not a compliance reset. Classification, origin, taxes and Canadian electrical approval all stay exactly where they were — and the duties on Chinese aluminum extrusions, which is what your racking is made of, were renewed only last October.
For eleven years, Canadian distributors and installers worked around a wall. Some paid to cross it. Most went around — buying from other countries, staying under the 100 W exclusion line, or quietly dropping product categories that were too much trouble to import.
That constraint is gone. What replaces it is an ordinary customs and engineering problem, which is a far better problem to own. Below is what changed, who gains, what did not change, and the specific mistakes we expect to see over the next two quarters.
The decision at a glance
| Question | Answer |
|---|---|
| What ended? | The CITT order supporting AD/CVD duties on certain Chinese PV modules and laminates |
| Effective date | September 17, 2026 |
| Case reference | Expiry review RR-2020-001, originating in inquiry NQ-2014-003 |
| Does it remove all import cost? | No. Normal customs treatment, taxes, origin rules and certification still apply |
| Does it cover racking and steel? | No — and the Chinese aluminum extrusions order was renewed on October 1, 2025 |
| Who gains most? | Importers, distributors, wholesalers, installers, EPCs and Canadian product brands |
What actually happened, step by step
The measure had a long life. Four Ontario manufacturers filed the original complaint in 2014. Duties landed in 2015 and were renewed in 2021. This year the machinery started up again — and then stopped early.
| Date | Event |
|---|---|
| December 2014 | CBSA opens dumping and subsidy investigations |
| July 2015 | CITT finds a threat of injury; duties take effect |
| March 2021 | CITT continues the order in expiry review RR-2020-001 |
| December 2025 | Interim review opens at the request of Kings Solar Solutions Inc. |
| March 13, 2026 | Order amended to exclude certain vehicle-mounted flexible modules |
| February 2026 | CITT and CBSA open a new expiry review |
| July 2, 2026 | CBSA finds dumping and subsidizing likely to continue or resume |
| September 17, 2026 | CITT terminates the review and rescinds the order |
Look hard at the last two rows. CBSA said the risk was real in July. The Tribunal closed the case anyway, well ahead of its own December 9 injury deadline. (CBSA, July 2, 2026)
That is not a contradiction — the two bodies answer different questions. CBSA asks whether dumping or subsidizing would likely resume. The Tribunal asks whether Canadian producers would likely be injured if the order expired. A customs broker bulletin on the outcome states it plainly: the Tribunal took the view that expiry would not injure the domestic industry, so the order was rescinded and SIMA duties stopped being payable as of September 17. (Livingston International)
Why the case collapsed, in plain terms
The public notice does not explain the reasoning. Anyone claiming to know it is guessing. The surrounding context, though, is not hard to read.
Canada still has domestic module production. Heliene builds in Sault Ste. Marie, Ontario as well as Mountain Iron, Minnesota; Silfab retains Toronto operations alongside its plants in Washington and South Carolina. So this was not a case of an industry that simply vanished. What did change is where each company put its growth — and how rough 2026 has been for both of them on the American side of the border. (Solar Power World, August 2026)
The clearer signal came a year earlier, and it is on the record. When Kings Solar Solutions asked to exclude flexible panels for curved vehicle surfaces, the domestic producers did not oppose it. In October 2025 they proposed widening the exclusion, to low-wattage modules generally. (pv magazine) · (Tax & Trade Blog)
An industry that wants a wall does not offer to move it.
Why this matters commercially: a measure that ends without a hard-fought defence tends to stay ended. From here, Canadian module supply gets shaped by buyer demand and engineering fit rather than by a duty schedule. The Tribunal’s full reasons are published on its decisions portal if you need the primary document for a compliance file.
The exclusion almost everyone missed
Six months before the order fell, it had already been cut back.
On March 13, 2026, the Tribunal amended the order to exclude flexible photovoltaic modules that will be affixed to curved vehicle surfaces — transport truck fairings, for example — with a power output not exceeding 200 W. (CITT, interim review RD-2025-001)
The amendment is mostly historical now. It still teaches something current. Canada’s trade system responded to a documented product gap: thin, bendable, adhesive-mounted panels that no Canadian factory builds. Fleet operators had a real sourcing problem, and one company took the trouble to file properly.
The takeaway for distributors is procedural rather than political. Trade measures have doors in them — exclusions, interim reviews and scope rulings are open to any importer with a well-documented case. Worth remembering the next time someone tells you a category is simply off-limits.
The Buyer Side
Five things Canadian buyers actually gain
1. Whole product categories come back
The old scope was broader than most people remember. It covered crystalline-silicon modules and laminates, including laminates shipped or packaged with other module components, plus thin-film products made from a-Si, CdTe or CIGS. That breadth is why certain products quietly vanished from Canadian catalogs — BIPV laminates, semi-flexible panels above 100 W, custom modules for equipment builders. Scope risk kills small orders faster than any duty rate, because one wrong call wipes out the margin on a whole shipment. Those categories are ordinary imports again.
2. The 100 W ceiling stops designing your products for you
Distributors serving RV, marine, off-grid and portable markets learned to range under that line. It was a customs artifact, not a customer requirement — and it carried real engineering costs, which the next section unpacks.
3. Genuine leverage with your current suppliers
This is the underrated effect, and it works even if you never buy a Chinese module. Any supplier who quoted you against a closed market now has an open one to justify their number. You do not need to switch. You only need to be credible about having options.
4. A technology catch-up window
Duty periods freeze markets in an older product generation. While Canada’s lineup stayed static, back-contact and other n-type cell architectures, dual-glass construction and glass-free flexible laminates all moved forward. Use the opening to upgrade what you offer, not just to re-price what you already sell. Distributors who treat this purely as a discount event will look identical to each other by spring.
5. Custom and OEM work becomes practical
Custom modules were the hardest thing to import under the old regime. Low volumes, odd sizes and one-off designs carried the same scope exposure as a full container of standard panels, with nowhere near the margin to absorb a mistake. Marine builders, RV manufacturers, equipment OEMs, BIPV designers and Canadian brands wanting their own label now have a workable path.
Engineering Perspective
The 100 W ceiling was a design distortion, not just a price problem
Most coverage of this decision talks about landed cost. The more interesting effect sat in the product design.
When a buyer needs 200 W on a van roof and the duty-free option tops out at 100 W, the buyer fits two panels. That choice carries consequences no datasheet shows:
- Lost area. Every laminate carries an inactive perimeter border. Two borders consume more of a fixed roof than one. On tight surfaces that alone can cost you a cell row.
- Double the junction boxes. Two boxes, two cable entries, two sets of bypass diodes, two potential water paths.
- Double the connector pairs. Field failures in small systems cluster at connectors and cable entries far more often than in the laminate itself.
- Mismatch. Two paralleled panels rarely see identical shade or identical temperature. The array follows the weaker one unless each has its own tracker.
- More labour. Two mounting frames, two bonding operations, twice the sealing work on a surface where every penetration is a risk.
One properly sized panel beats two small ones on nearly every metric that matters in a mobile or marine install. The old duty line pushed the whole Canadian aftermarket toward the weaker configuration.
The charge-controller trap that follows
Here is the part that catches resellers moving up in panel size for the first time.
Traditional 12 V-nominal panels use a 36-cell string and sit around 17–18 V at maximum power. They tolerate a cheap PWM controller. Larger modern panels — including most half-cut and back-contact designs above 100 W — commonly land in the low-to-mid 20s at Vmp. A PWM controller is essentially a switch: it pulls the array down to battery voltage, so current stays roughly the same while the surplus volts are simply discarded. Victron’s own comparison of the two topologies walks through the arithmetic. (Victron Energy)
What to avoid: shipping a larger panel into an existing PWM-based kit and letting the customer discover the shortfall in July.
Read Vmp on the datasheet, not the nominal-voltage label in the product title. If Vmp sits meaningfully above battery charging voltage, the kit needs MPPT. Update the bundle before you update the catalog.
Impact by buyer type
| You are a… | What changes | Your first move |
|---|---|---|
| Importer of record | Direct sourcing is viable; the documentation burden is unchanged | Get written entry guidance from your broker |
| Distributor / wholesaler | Wider range, especially laminates and larger flexible formats | Rebuild the line card; requalify two or three suppliers |
| Installer / contractor | More choice; approval rules untouched | Verify certification for each exact model you quote |
| EPC / developer | Module sourcing opens; the metalwork carries the remaining duty risk | Split the BOM by customs line before pricing |
| Product brand / OEM | Private label and custom builds become realistic | Scope a pilot run, not a container |
| Marine / RV retailer | The 100 W habit no longer constrains the range | Range by footprint and Vmp, not by old duty limits |
The Overlooked Risk
Your duty risk just moved from the panel to the rail
This is the single most important paragraph in the article for anyone quoting a full system.
On October 1, 2025 — five and a half months before the module order fell — the same Tribunal continued, with amendment, its order on aluminum extrusions from China. It found that expiry would likely result in injury, so CBSA continues to impose anti-dumping and countervailing duties on those goods. (CITT, October 1, 2025) · (CBSA statement of reasons)
Read those two decisions side by side and the picture is clear. Two Chinese products, two Tribunal panels, two opposite outcomes, six months apart.
Mounting rails, mid-clamps, end-clamps, L-feet, splices and frame stock are aluminum extrusions. Whether a given part falls inside the legal scope turns on alloy, cross-section, wall thickness, fabrication and tariff classification — not on whether the invoice says “solar mounting system”. Steel piles, ground screws and fasteners have their own separate measures to screen against, and Canada operates surtax orders on listed Chinese steel and aluminum goods that sit on top of any SIMA liability.
Practical consequence: a container that used to be “risky panels, simple metalwork” is now the reverse.
Quote every system as separate customs lines and get an HS and SIMA screening on each significant metal item. One broad “solar system” classification is now the expensive option.
Canada-Specific Design
Buying direct means you now own the cold-climate spec
When you buy through a Canadian distributor, somebody upstream has usually already filtered the catalog for Canadian conditions. Buy direct and that job becomes yours. Three items decide whether a module belongs on a Canadian roof.
Open-circuit voltage at winter design temperature
Voc rises as cell temperature falls, so a string hits its annual voltage peak on a clear, still January morning — before it makes any useful power. Modern crystalline modules publish Voc temperature coefficients roughly between −0.20 and −0.28 %/°C. Take a module at a −30 °C cell temperature, 55 degrees below STC, and that translates to somewhere around 11% to 15% above its rated Voc. That directly reduces how many modules you may place in a string under the system voltage ceiling, and Section 64 of the Canadian Electrical Code is where the requirement lives. Ask the supplier for the coefficient in %/°C and run the arithmetic against your own provincial design temperature — never against a calculator’s default.
Snow and mechanical load, stated properly
A mechanical load rating is not a universal permission. It applies to the tested mounting configurations described in the installation manual — clamp positions, rail spacing, frame orientation. Change the mounting and the rating no longer describes your system. Read the load figure together with the manual and your local snow-load code, then keep both on file for the authority having jurisdiction.
Bifacial gain over snow is a Canadian argument
Dual-glass bifacial modules are one of the categories this decision reopens, and Canada is one of the few markets where the rear-side case is genuinely strong rather than marginal. Bifacial gain rises with ground albedo, array height, row spacing and module spacing, and snow-covered ground is about the highest albedo a site will ever see. (IEA-PVPS Task 13)
Canadian field work backs this up. A Western University study that photographed two side-by-side arrays through an Ontario winter found monofacial snow losses averaging about a third over the winter period, while the bifacial array cut annual snow losses to around 2% and showed roughly a 19% winter gain over its monofacial twin. (pv magazine USA)
Two honest caveats before you put that in a proposal. It is one site and one winter, so treat it as directional rather than as a design figure. And rear-side irradiance is far less uniform than front-side, which introduces electrical mismatch — so array geometry and string layout decide how much of the theoretical gain you actually collect.
What did not change
This is where confident people lose money. The order fell. The rest of the import file is fully intact.
- Origin still matters. The old order applied to goods originating in or exported from China. That specific exposure is gone. Origin declarations, classification and recordkeeping are not — CBSA audits entries long after release.
- Metal balance-of-system parts carry live measures. Covered in detail above. The aluminum extrusions order was renewed in October 2025.
- Taxes and ordinary duty apply as before. GST at import, provincial requirements, brokerage and freight all sit where they always did.
- Provincial and utility programs set their own rules. Incentive programs and approved-equipment lists are administered independently of federal trade policy. A module can clear customs and still be ineligible for a rebate.
An IEC test report is not Canadian approval
This one misunderstanding stalls more shipments than any tariff ever did, so it is worth being precise.
Electrical products sold or imported in Canada must meet the Canadian Electrical Code, and an authority having jurisdiction normally bases its acceptance on certification by a body accredited by the Standards Council of Canada. IEC test reports are an input to that certification, not a substitute for it. A supplier who sends you a test report has given you evidence, not approval.
Where certification is impractical, CSA SPE-1000 provides a field-evaluation route through an SCC-accredited inspection body. Read its scope before you build a business on it. The code states outright that field evaluation is not a substitute for certification, and it frames the route around limited-quantity cases — custom equipment, non-repetitive production, and equipment sold in quantities of not more than 500 nationally, per model, per year, per inspection body. (CSA SPE-1000)
Practical reading: field evaluation is a project tool. Certification is a distribution strategy. Choose based on how many units of one model you expect to move in Canada each year — the code has effectively drawn that line for you.
One more trap: approval attaches to a specific model and construction. A sister model, a different backsheet, a new junction box or a changed cell layout may each require re-evaluation. “Same factory” is not “same approval”.
Two customs details worth copying into your file today
One government page is out of date — do not price from it
As of this writing, CBSA’s “Measures in Force” page for photovoltaic modules and laminates still reads as an active measure, carrying a last-modified date of March 17, 2026, complete with duty-liability tables and exporter listings. (CBSA SML page) It has not caught up with the September order, and search engines will keep serving it for weeks. The Tribunal’s order and CBSA’s release and accounting instructions control. A web page does not.
Know which heading your product actually falls under
That same page lists the two tariff classification numbers normally used for these goods: 8541.42.00.00 for photovoltaic cells not assembled into modules or made up into panels, and 8541.43.00.00 for cells assembled into modules or panels. The distinction is physical, not commercial. What you call a product in your catalog carries no weight at the border.
Three product families sit near that boundary and deserve a written scope note in your file:
- Bare laminates for building or vehicle integration, shipped without frame or junction box.
- Integrated goods — a solar light, a portable power station, a sensor with a small panel — where power generation is not the device’s function.
- Kits shipped with controllers, cable and mounting parts in one carton, each component potentially classifiable in its own right.
Historic disputes in this case file turned on exactly these edges, which is why CBSA publishes subjectivity re-determinations. (CBSA re-determinations) The duty is gone. The classification discipline should stay.
Act This Week
The question almost nobody is asking: what about duty already paid?
If you imported covered goods earlier in 2026 and paid SIMA duty, raise this with your broker today.
Expiry reviews must begin before a measure’s scheduled expiry date, and the order under review was made on March 25, 2021. In this same case file, CBSA’s earlier expiry-review statement set out the standard consequence of a rescission: duties would no longer be levied, and duties paid on goods released after the date the measure was scheduled to expire would be returned to the importer. (CBSA statement of reasons)
Meanwhile, the broker bulletin on the new decision states that duties stopped being payable as of September 17, 2026. Those two statements point at different dates.
Only CBSA can resolve which treatment applies to your entries, and the answer turns on release dates and accounting timing. But for any importer with covered entries this year, this is the largest open item on the table — and nobody is going to raise it on your behalf.
Ask one direct question, in writing: “For our entries of covered goods this year, is any SIMA duty refundable, and what is the deadline to apply?”
Seven mistakes we expect to see this quarter
None of these are hypothetical. Each has a precedent from a previous trade-policy shift somewhere in the world.
- Marketing modules as “duty-free.” Inaccurate, and it invites a dispute the day a customer’s broker disagrees. Say the order was rescinded, and that landed cost remains subject to classification, origin, tax and compliance review.
- Pricing from the stale Measures in Force page. Price from written broker guidance instead.
- Assuming the module decision covers the racking. It does not, and the aluminum extrusions order was renewed five months earlier.
- Assuming a third-country shipping route changes origin. Origin follows manufacture and substantial transformation, not the port of loading.
- Buying to a datasheet instead of to a model number. Datasheets describe families. Approvals, warranties and test reports attach to specific models and constructions.
- Treating field evaluation as a volume strategy. It is a limited-quantity route by design.
- Quoting a rebate-dependent job before checking the approved-equipment list. Trade policy changed. Program eligibility did not.
Your 10-point import readiness checklist
Work through this before the next purchase order, not after the container lands.
- Confirm the effective date and treatment for your intended entry, in writing, from your broker.
- Ask about refunds on covered entries already made this year.
- Classify per product, not per shipment.
- Split the BOM into separate lines: modules, rails, clamps, piles, fasteners, cable, inverters, batteries.
- Screen every metal item against the aluminum extrusions and steel measures, then against the surtax schedules.
- Check certification per model, not per factory.
- Confirm program eligibility before quoting any rebate-dependent job.
- Collect the origin package: invoice, packing list, bill of lading, BOM, manufacturing-location statement, serial list.
- Qualify the paperwork: test reports, warranty terms, and the legal entity that stands behind them.
- Sample before you scale. One pallet through your full customs and approval process teaches more than any quotation.
How to requalify a Chinese supplier now
The duty used to do your filtering. It filtered badly, but it filtered. That job is yours now, and six questions separate a manufacturer from a trading desk fairly quickly.
- Who makes it? Factory name, plant location, and whether cells are made in-house or purchased.
- What exactly is this model? Full STC electricals, power tolerance, temperature coefficients, dimensions, weight.
- What test evidence exists for this model? Reports with dates and revision numbers — not marketing claims.
- Who honours the warranty? Name the entity and the claims process.
- What happens at low volume? MOQ, sampling lead time, and whether custom sizes are genuinely available.
- What will you not promise? The answer to this one tells you the most.
For custom, flexible or non-standard formats, add a change-control question: what resets qualification if I alter the size, the cell count, the backsheet or the connector? Some changes are trivial. Others send the product back through testing. A serious manufacturer draws that line for you before you order, not after.
Could the duties come back?
Yes, and a sensible buyer plans as though they might.
A rescission is not permanent immunity. Any domestic producer can file a fresh complaint if conditions change. Canada also operates surtax orders that work separately from trade remedies, and government consultations on Chinese clean-energy products have happened before. A consultation is not a measure — but it is a signal, and signals are cheap to monitor.
Three habits protect you:
- Keep clean origin and classification records for every entry.
- Avoid single-source dependence on any one country or supplier.
- Write contracts that say who carries the cost if a new duty or surtax appears mid-order.
That last point is the one distributors skip and later regret. Settle it in the purchase order, not in an email afterwards.
Frequently asked questions
Are Chinese solar panels now duty-free in Canada?
No. The specific anti-dumping and countervailing duties under order RR-2020-001 no longer continue. Normal customs treatment, taxes and compliance requirements still apply.
Can I legally import Chinese solar panels into Canada in 2026?
Yes — importing them was always legal, the issue was the duty. What governs your shipment now is ordinary customs law plus Canadian electrical approval for the exact model, and provincial program rules if the end customer expects an incentive.
What exactly did the old order cover?
Crystalline-silicon PV modules and laminates, laminates shipped or packaged with other module components, and thin-film products made from amorphous silicon, cadmium telluride or copper indium gallium selenide, originating in or exported from China.
Were small panels ever affected?
Modules, laminates and thin-film products not exceeding 100 W were excluded from the start. A narrowly specified 195 W monocrystalline module was also excluded, as were PV products built into devices whose function is not power generation.
Can I now import flexible panels above 100 W?
Yes, subject to normal customs and safety requirements. Note that certain vehicle-mounted flexible modules up to 200 W had already been excluded in March 2026.
Does this change anything for racking or mounting hardware?
No — and this is the part most buyers get wrong. The Tribunal continued its order on Chinese aluminum extrusions on October 1, 2025, so rails, clamps and frame stock can still attract anti-dumping and countervailing duties. Steel components and surtax schedules need separate screening.
Do I still need CSA or cUL certification?
For anything installed under the Canadian Electrical Code, yes. Approval normally comes from a certification body accredited by the Standards Council of Canada. An IEC test report supports that process but does not replace it.
Will a Chinese module qualify for provincial incentive programs?
That depends on the program, not on trade policy. Check the approved-equipment list and the certification requirement for your exact model before quoting.
How quickly will supply and availability reflect this?
Supply chains move faster than catalogs. Expect supplier requalification, certification and program listing to be the slow steps — not the sourcing itself.
Should I still keep a non-Chinese supply option?
Yes. Diversification is cheap insurance, and it keeps negotiations honest on both sides of the table.
Key Takeaways
What to remember
- Canada’s AD/CVD order on covered Chinese PV modules and laminates was rescinded on September 17, 2026.
- The biggest gains sit with importers, distributors, installers and Canadian product brands.
- Laminates, larger flexible formats and custom modules return as ordinary imports.
- Your remaining duty risk moved to the metalwork — the Chinese aluminum extrusions order was renewed in October 2025.
- Dropping the 100 W habit changes your charge-controller spec. Read Vmp before you change the bundle.
- Certification, origin, classification and provincial program rules are untouched.
- If you paid SIMA duty on covered goods earlier this year, ask about refunds now.
How this article was checked
Every date, scope detail and procedural step comes from the Tribunal’s own releases, CBSA case pages, a customs broker bulletin and contemporaneous trade press. Each link below was opened and verified before publication.
Three points are deliberately left open rather than settled. The Tribunal has not published a plain-language explanation of why it terminated the review. The treatment of duty already paid in 2026 requires confirmation from CBSA for each importer’s own entries. And the Canadian bifacial snow-loss figures come from a single site over a single winter, so we present them as directional rather than as design inputs. Engineering guidance here is general and format-independent — confirm every figure against the specific datasheet and installation manual you are buying to.
Nothing in this article is legal, customs or tax advice. Confirm your position with a licensed Canadian customs broker before shipping.
Sources: CITT news release, September 17, 2026 · CITT order (RR-2020-001) · CITT interim review, March 13, 2026 · CITT order (RD-2025-001) · CITT, aluminum extrusions continued, October 1, 2025 · CBSA aluminum extrusions statement of reasons · CBSA Measures in Force (PV modules and laminates) · CBSA notice of conclusion, July 2, 2026 · CBSA expiry review statement of reasons · CBSA guide to self-assessing SIMA duties · CBSA subjectivity re-determinations · CBSA Measures in Force index · CSA SPE-1000 · Victron Energy, PWM vs MPPT · IEA-PVPS Task 13, bifacial modules and systems · pv magazine USA, bifacial performance in snow · Livingston International · pv magazine · Tax & Trade Blog · Solar Power World
Working With a Manufacturer
Bring us the constraint, not the wattage
The Canadian market just moved from a closed question to an open one. The suppliers worth your time are the ones who answer the hard questions in writing — and who tell you which design changes reset qualification before you place the order.
Couleenergy builds back-contact modules to order: flexible ETFE laminates, rigid BC modules, dual-glass bifacial and custom OEM formats. We work at pilot volumes as well as container volumes, which is exactly what a new market entry needs.
Send us the surface, the available space, the system voltage and the mounting method. We will tell you what is buildable, what needs testing, and what we would not recommend.
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