The United States Department of Commerce(USDOC) issued the preliminary determination on anti-dumping of crystal silicon photovoltaic (PV) cells made in China on May 16, 2012 American Time, declaring that anti-dumping rate for Chinese enterprises is 31.14%-249.96%, and it therefore determined to take temporary anti-dumping measures against such products. Although USDOC accepted some materials submitted by Chinese enterprises, the China-based PV industry believes that the determination distorts its manufacturing and exporting status. Therefore, CCCME, on behalf of China-based PV industry makes the following statements.

 

        Recent years have witnessed the enlarging export volume of Chinese PV cells to the U.S. market and its appeal to American consumers. Chinese PV enterprises are committed to quality and technical innovation, which assures Chinese industry possess in the state-of-the-art of technologies such as silicon ingot manufacturing technology, metallurgical polysilicon, high-efficiency solar cell, SE, ESE, MWT and so on.

        The very reason China-based PV industry enjoys competitive advantages is the concentrated development, first-class management, scale economy and prospective strategy. Chinese enterprises have no intention, haven’t and will not resort to low price competition, including dumping, to share the market.

        USDOC determined such a high dumping margin mainly because it denies Chinese Market Economy Treatment, ignores the fact that Chinese companies operate following the rule of market economy, and applies the cost of companies from a subrogate country for unfair competition. On this unreasonable ground, USDOC determined the existence of dumping and calculated dumping margin for Chinese companies. This approach is inconsistent with the status quo of China’s market economy and highlights the trend of U.S. trade protectionism.

 

        Chinese responding enterprises have participated in the onging anti-dumping investigation of USDOC by various means, responding actively and cooperatively. However, we firmly believe that Chinese responding enterprises’ rights and interests have not been fully guaranteed.

        USDOC adopted the discriminatory policy of “surrogate country”, designated the surrogate country arbitrarily and determined the comparable price on the foregoing ground. When designating the surrogate country, USDOC has not taken full consideration of industry size, grade of maturity and industrial comparability. This approach ignored the status quo of Chinese economy and PV industry, distorted the production cost severely, was result-oriental and arbitrary, which determines the preliminary duty unacceptably high. Therefore, Chinese enterprises express strong opposition.

        We hold that if USDOC addressed the status quo of Chinese PV, determined the normal value of Chinese products fairly and reasonably, Chinese companies would prove no signs of dumping practices with unshakably evidence.

 

       The drop of crystalline silicon PV cell and module prices in the U.S. is primarily the result of the drop of the price of poly-silicon due to global oversupply. In addition, competition of thin-film PV cells, incentive policies and financial aids of the Federal and state governments in the U.S., consumer’s demand, competition of other alternative energies have also contributed to the drop of crystalline silicon PV cell and module prices.

       Solarworld cannot represent the U.S PV industry. As far as CCCME knows, the leading U.S. PV manufacturers and Solar Energy Industries Association that represents more than 1000 U.S. manufacturers, have expresses strong opposition for the preliminary determination. The aforementioned parties regard this determination as short-sighted and a serious setback for the promotion of clean and renewable energy policy by Obama Administration. Chinese PV products have made great contribution to the popularization and promotion of such products in the U.S market. The solar industry in the U.S. generates approximately 100,000 jobs, while in comparison SolarWorld provides only 1,000 jobs. If the U.S. market were denied access to PV cell products of competitive prices, other 99,000 jobs would be put into a dangerous situation. That is exactly why SolarWorld’s petition is opposed by U.S. companies from upstream raw material and equipment suppliers to downstream distributors, installators and users. Similarly, consumers looking forward to affordable solar products, environmental organization and climate experts have expressed opposition.

        CCCME has organized 14 Chinese enterprises to respond to this investigation. We are committed to unite together and to demonstrate that China-based PV industry causes no injury to the U.S domestic industry with strong facts and evidences.

 

       As pointed out by Chinese PV enterprises, Chinese PV industry has greatly contributed to the development of global PV market. To produce crystal silicon photovoltaic cells, China imports more than USD 2 billion of polysilicon, EVA, sizing agent and other raw materials from the U.S. every year. The PV industry equipment imported from the U.S. to China and the technology licensing costs paid by Chinese companies were no less than USD 3 billion in 2010. Besides, the export of Chinese PV cells and components stimulates the development of American downstream industries (especially the PV generating installation industry). Therefore if the American government imposes trade restriction measures on Chinese crystal silicon photovoltaic cells, it will have adverse impact to global PV energy market, especially the U.S industry.

 

China-based PV enterprises wish that USDOC will adjust its incorrect and unfair practices in the ongoing investigation, treat Chinese companies and their responses objectively and impartially and avoid the infringement of legitimate rights and interests of Chinese responding enterprises. Meanwhile, China-based PV enterprises will unite together, respond actively and strongly in the anti-dumping and countervailing investigation, exhaust all efforts to protect legitimate rights. In addition, Chinese PV enterprises are fully committed to create a favorable trade orders and push the global PV industry forward to a better future together with PV enterprises all around the world.