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Let us first review the background of the "No. 58 text". In January of this year, the Ministry of Commerce announced the results of anti-dumping and counter-subsidy final rulings, and imposed a “double-reverse†tax rate of 53.6%-59.1% on US solar-grade polysilicon export enterprises. However, the proportion of polysilicon imported through processing trade (to circumvent anti-dumping duties) accounted for a large increase in the total amount of polysilicon imports in China. The “double-reverse†measures seem to have little effect. Solar-grade polysilicon is imported by processing trade, and can also avoid import tariffs of 4% of general trade channels. Therefore, polysilicon imported from processing trade can be sold in the Chinese market at a lower price.
From the comparison of export data of polysilicon imports and photovoltaic modules to the United States, South Korea and Germany, a large proportion of polysilicon is imported from these three countries in the form of processing trade, but few corresponding battery component products are returned to these countries. Therefore, the impact of the polysilicon processing trade policy on promoting or weakening the export of photovoltaic products is limited. The related enterprises use the tax-free policy of processing trade materials to import polysilicon, but the battery and component products are not returned when they are exported, but they sell independently, and even export according to general trade, get 13-17% of export tax rebate, two ends Profit.
It is precisely this situation. On August 14, the Ministry of Commerce and the General Administration of Customs issued the No. 58 Announcement of 2014, “Decision on Suspension of Application for Import of Imports of Solar-Grade Polysilicon Processing Trade†(No. 58), adopting trade. Relief measures to curb such trade violations. At the same time, taking into account the actual situation of each enterprise, the implementation of the networked supervision enterprise with the enterprise as the management unit is limited to December 31, 2014.
Unexpectedly, the trend of large-scale imports of solar-grade polysilicon has not only been blocked, but has intensified. According to the latest report released by the China Nonferrous Metals Industry Association Silicon Branch, the total amount of China's polysilicon imports in September was 9,942 tons, an increase of 18.7% from the previous month and a record high. Among them, solar-grade polysilicon imported from the United States reached 1,698 tons, except for 189 tons of polysilicon for semiconductors that are not within the scope of anti-dumping. All others were imported by processing trade.
In order to continue the dumping trend against China, foreign polysilicon exporters use China's processing trade policy channels to circumvent the "double opposition" and find ways to rush to approve before September 1. It has been learned from several provincial-level photovoltaic industry associations that after the introduction of the “No. 58 Documentâ€, foreign polysilicon giants have signed a large number of multi-processing trade contracts with domestic PV manufacturers, and the deadline exceeds the provisions of Circular 58. At the end of the year, after 2015, these processing trades were approved by the municipal-level commercial departments below the provincial level in the two weeks after the document was released. This is clearly challenging the No. 58 document, challenging customs tax regulation.
The original intention of Circular 58 is to consolidate the effect of polysilicon “double anti-reverseâ€, and also to fair competition opportunities in China's polysilicon industry, to consolidate the raw material foundation of the photovoltaic industry, and to make the domestic PV industry chain more balanced and healthy. As the Ministry of Commerce's double tax rate against South Korea's major polysilicon exporter OCI is only 2.4%, and Germany's major polysilicon exporter WACKER reached a price commitment agreement. Therefore, the suspension of polysilicon processing trade has little effect on the export of polysilicon from these two Germany and South Korea, but it has a great influence on the export of US polysilicon to China. It is no wonder that we recently saw experts from SEMI, an international organization headquartered in California, open in China. The official media economic daily newspaper questioned. However, we know that about 20,000 tons of polysilicon raw materials imported from the United States to China in 2013, and if measures are taken, this gap can be fully filled by the increased output of domestic enterprises in 2014. From the second half of 2013, the major domestic polysilicon leading enterprises will resume, increase production capacity and output. According to the actual production statistics from January to October, the China Nonferrous Metals Industry Association Silicon Industry Branch is expected to produce more than 120,000 tons of domestic polysilicon enterprises in 2014. In 2013, the net increase was 40,000 tons.
China's polysilicon industry has experienced nearly 10 years of development, and product quality has developed rapidly in this process, fully meeting the demand for materials used by photovoltaic companies. At present, most of the companies still operating in Jiangsu Zhongneng, Xinjiang Daquan, TBEA, Tianhong Silicon, and Luoyang Zhongwa can produce polysilicon products that meet the national electronic standards and uses, and can completely replace imported products. Combined with the improvement of the quality of polysilicon products, the level of domestic crystal growth and slicing technology is also increasing day by day, and the silicon content and processing cost per watt of silicon wafers have dropped significantly. The proportion of polysilicon in the entire photovoltaic industry chain is also decreasing. The price increase brought by polysilicon “double reverse†is limited, and the impact on the domestic PV industry chain is also minimal.
Therefore, strict implementation of Circular 58, even if the import volume is reduced, but the market supply and demand will remain balanced, will not cause sharp fluctuations in market prices, from the polysilicon prices in these months are very clear.
Some experts in the industry have mentioned that the "double-reverse" of polysilicon has caused the mid-stream and downstream manufacturing enterprises to be forced to build factories overseas. This is a kind of reversal of cause and effect and confusion. As we all know, China's Ministry of Commerce adopts polysilicon "double-reverse" is a counter-measure against the United States' two "double anti-" measures against China's photovoltaic products, while China's middle and lower-end PV manufacturers are also actively responding to the US "double opposition." Seeking overseas construction is one of their measures to deal with the "double opposition" by Europe and the United States. This is consistent with the Ministry of Commerce's goal of responding to the "double opposition" of US polysilicon. Polysilicon "double-reverse" has led to the forced construction of factories in the middle and lower reaches of photovoltaics, which is completely nonsense.
Some people in the industry are worried that polysilicon "double anti-" will promote the monopoly position of polysilicon leading enterprises in China. We know that an active market is more conducive to competition. China's polysilicon enterprises used to be as many as 15 in the 1970s, but they are very weak. They have closed down under the pressure of international polysilicon giants. The entire global polysilicon industry has been in the semiconductor era. The development of more than 70 years is from the history of industrial dispersion to concentration, but there is no Chinese enterprise among the seven international giants born in history. When the Chinese PV industry broke out, the raw materials were subject to people and the price was very high. It was the participation of Chinese leading enterprises that changed the competition. In the pattern, China Polysilicon has been able to serve PV companies and consolidate the raw material base of China's PV. Before the "double-reverse" of polysilicon, foreign polysilicon manufacturers dumped the domestic market at a low price. More than 40 polysilicon enterprises above the scale could not withstand the impact of four foreign polysilicon enterprises. There are only a handful of companies that can produce. After the "double anti-", many companies resumed production, the association statistics reached 15, and GCL-Poly, TBEA, Daquan and other companies also launched expansion plans. While domestic polysilicon enterprises are making big cakes, more companies have participated in them, and the industry has shown a good momentum of orderly competition and sustainable development.
Polysilicon "double anti-" and subsequent suspension of solar-grade polysilicon processing trade import business application acceptance, not only contribute to the healthy development of the domestic polysilicon industry, but also fully compensate for the overseas (US-based) polysilicon imports in quantity and quality. influences. The relevant import and export enterprises are called upon to strictly implement the time regulations of the National No. 58 Document and maintain the stability of the domestic polysilicon market. 
China Silicon Industry Association: Polysilicon processing trade closed at the end of the year
Abstract From the data of polysilicon import in September, China's suspension of solar-grade polysilicon processing trade import business application acceptance (Ministry of Commerce, General Administration of Customs No. 58 Announcement No. 58 of 2014), the implementation of "double anti-" on imported polysilicon did not expect. ..
Judging from the data on polysilicon imports in September, China's suspension of solar-grade polysilicon processing trade import business application acceptance (Ministry of Commerce, General Administration of Customs No. 58 Announcement No. 58 of 2014), and the implementation of "double opposition" on imported polysilicon did not have the expected effect. In public opinion, some people in the domestic PV industry have proposed a discordant argument against this trade remedy introduced by the state. Even experts from international organizations SEMI are openly challenged.