ACORE to Sec. Raimondo: Conclude the Inquiry Promptly With a Final Negative Determination

WASHINGTON, D.C. – The American Council on Renewable Energy (ACORE) formally submitted comments today expressing multiple concerns with the Department of Commerce’s initiation of a circumvention inquiry on solar imports.

“As a result of the immense cost uncertainty unleashed by this decision, we are already seeing a dramatic and immediate decrease in the investment in and development of solar energy in the United States. Businesses are unable to make financial decisions concerning investment in new solar projects when the costs are unknowable – and could more than double without notice. The decision also has an immediate impact on the availability of new solar modules in the U.S., with global suppliers predictably choosing to ship their solar products to other nations where there is not the same risk of punitive tariffs,” wrote ACORE President and CEO Gregory Wetstone.

The letter documents how Commerce has provided inadequate substantiation of the initiation of this inquiry, noting that the case falls short on two key counts:  1) whether the process of assembly or completion in the third country is “minor” or “insignificant”, and 2) whether the petition passes the “appropriateness” test for expanding an existing AD/CVD order.

“It is disappointing that Commerce relied on such a tenuous basis and considered only the views of a single small company in launching an inquiry with such devastating impacts,” Wetstone writes. “Given the absence of a clear justification, the paralyzing impacts on a sector of the economy that had previously been an important national economic driver, and the threat to achievement of decarbonization goals, we urge Commerce to conclude the inquiry promptly with a final, not preliminary, negative determination.”

ACORE member companies hold more than $25 trillion in assets and, in 2021, more than 90 percent of the booming utility-scale U.S. renewable growth was financed, developed, owned or contracted for by ACORE members.

To download a copy of the submission, click here


About ACORE:
For more than 20 years, the American Council on Renewable Energy (ACORE) has been the nation’s premier pan-renewable nonprofit organization. ACORE unites finance, policy and technology to accelerate the transition to a renewable energy economy. For more information, please visit

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