Geopolitics & Trade

China Solar Export Controls 2026: What Is Banned, What Is Allowed

Shashank·Founder·October 17, 2026·10 min read

China's Solar Export Controls at a Glance

On October 16, 2026, China's Ministry of Commerce (MOFCOM) and Ministry of Science and Technology (MOST) published Announcement No. 48 of 2026. It proposes revising the Catalogue of Technologies Prohibited or Restricted from Export to add 40 technologies across three sectors: 23 in artificial intelligence, 12 in photovoltaics and five in biomedicine. Across all three sectors, 14 technologies would be prohibited and 26 restricted, according to the ministry's spokesperson.

For solar, the 12 technologies cover polysilicon manufacturing, silicon wafer production and solar cell manufacturing. The controls also reach the key and core equipment that carries those technologies. This is the China export controls solar story in one sentence: the target is the know-how and the machines that make polysilicon, wafers and cells, not the panels themselves.

Two clocks are running.

Consultation: the public may comment from October 16 to November 15, 2026. That is 29 days from today. The deadline is not a date when the final catalogue takes effect, and no effective date has been announced.
Registration: a temporary pre-export registration rule applies from the date of the announcement until the revised catalogue is formally issued and takes effect.

The catalogue is not in force. The registration rule is.

What Is Banned and What Is Restricted

The draft sorts the 12 solar technologies into two tiers. Prohibited technologies cannot be exported. Restricted technologies need an export licence. The table lists what each tier covers, using the thresholds as the draft states them.

Tier	Solar technology in the draft	Threshold examples
Prohibited	Polysilicon preparation: cold hydrogenation fluidised-bed and silane fluidised-bed processes, and the technology to make their equipment	Single-line capacity of at least 250,000 tonnes a year for the trichlorosilane process and at least 20,000 tonnes a year for silane
Prohibited	Silicon wafer preparation technology, including program code, algorithm models and equipment drawings	Wafers 70 micrometres thick or thinner
Prohibited	Edge-passivation technology for crystalline silicon cells, and its equipment technology	Wafer sides of 182 to 230 mm and thickness of no more than 140 micrometres
Prohibited	Perovskite and tandem cell module production technologies, and their equipment technology	Tandem cells on 182 mm wafers at 30% efficiency or more, slot-die coating of 1.1 m width or more, one-square-metre perovskite modules at set efficiency levels
Restricted	Polysilicon engineering technology and reduction processes	Production lines of at least 30,000 tonnes a year, reduction reactors of at least 800 tonnes a year
Restricted	Monocrystalline ingot pulling, ingot machining and ultra-thin wafer slicing, with their equipment technology	Furnace chambers of at least 1,600 mm, ingots at least 720 mm long, wafers 130 micrometres or thinner, tungsten wire of 28 micrometres or finer
Restricted	TOPCon and XBC cell process technologies: LPCVD and PECVD coating, atomic layer deposition, high-temperature boron diffusion, copper electroplating	Throughput set per process on a G12 full-wafer basis, for example 4,500 wafers an hour for boron diffusion
Restricted	Heterojunction (HJT) cell technologies: transparent conductive film and silicon film deposition, silver-coated copper, copper electroplating	Wafers 110 micrometres or thinner, with indium, crystallinity, throughput or efficiency criteria

Each sub-item has its own conditions, and the conditions in one entry should not be stacked onto another. The scope also lists named equipment, including fluidised beds, reduction furnaces, monocrystalline furnaces, ingot machining and wafer slicing machines, edge-passivation equipment, deposition, diffusion and electroplating equipment, and slot-die coating equipment. Controls apply to that equipment only where it carries technology meeting the thresholds.

Technology that is already in the public domain through open source or academic publication is outside the scope.

Is China Banning Solar Panel Exports?

No. The draft concerns technology transfers and listed equipment. The ministry's spokesperson said products manufactured using the listed technologies are not subject to the controls. The SMM analysis reads it the same way: the measures are not a blanket ban on exports of polysilicon, wafers, cells or modules.

That is why the phrase "China solar export ban" overstates the case for most buyers. Modules and cells shipped from China remain outside the draft. What the draft touches is the transfer of the processes and machines used to build the factories that make them. An EPC buying finished modules is therefore not the party the rule is written for.

How the Interim Registration Works Now

The registration rule is the part that already bites. From October 16, anyone exporting a technology listed in the annexes must register the export with MOFCOM before proceeding, through the Technology Trade Management Information System on its unified business platform. The rule also covers exports that began before October 16 and are not yet complete.

Four kinds of transaction must be registered: transfers of technology ownership to overseas entities, licensing of technology for use overseas, changes in ownership or control that make an overseas entity the owner or controller, and other cases MOFCOM designates. The registration records the exporter and the recipient, the destination, the technology and its intended use, and the estimated value. Exports of listed key and core equipment must also be registered.

Registration is not approval. The SMM analysis notes that registering does not by itself confer an export licence. Whether a technology ends up prohibited or restricted will depend on the final catalogue.

The ministry also explains why registration matters for plants abroad. Exports of key solar technology often travel with the export, installation, commissioning, modification and upgrading of production lines. Exporters in those situations must apply for technology export licences and use the paperwork to complete foreign exchange, banking, tax and customs steps.

What It Could Mean for India's Solar Manufacturing and ALMM

For Indian EPCs the link runs through ALMM. India's rules push net-metering, subsidised and government-linked projects toward domestically made modules and cells, and the supply of those depends on factories that use technology and equipment with Chinese roots.

The facts on the Indian side:

ALMM List-II (cells): the list reached 37,393 MW of enlisted cell capacity in October 2026, after MNRE added 529 MW of Mono-PERC capacity. TOPCon capacity is also being added.
Net-metering and open-access exemption: MNRE exempted these projects from List-II until December 31, 2026. Projects commissioned after that date need ALMM-listed cells as well as ALMM-listed modules.
ALMM List-III (ingots and wafers): MNRE's March 2026 order, announced through PIB, makes ALMM-listed wafers mandatory from June 1, 2028, including for net-metering and open-access projects. The initial list will be issued only once at least three independent manufacturers with a combined 15 GW are operating, each with matching ingot capacity.

The draft controls sit directly on the technologies that India's wafer and cell build-out needs: ingot pulling, wafer slicing and TOPCon process steps. The SMM analysis frames the risk as ramp-up, not shutdown. Plants that finished their technology transfers and run normally need not stop. Plants that still depend on transfers from China, for commissioning, yield improvement or upgrades such as thinner wafers, copper electroplating and lower silver use, could reach design output later or lower costs more slowly.

Two limits apply. First, no source read here names Indian manufacturers that depend on controlled technology, so this guide makes no claim about any company. Second, SMM says a rise in module prices is not an automatic consequence. The channel is qualified output and cost reduction at new plants, and it depends on which transfers fall inside the final thresholds.

For an EPC, the practical reading is about supply timing. A cell or wafer plant that ramps up late can delay when List-II cells, and later List-III wafers, are available at scale. That matters most for projects that must be commissioned with ALMM-listed cells after December 31, 2026.

What It Could Mean for US Solar

The US side is less direct. The draft does not cover finished modules sold into the US, and our Section 232 guide covers the separate tariff and minimum import price rules that start December 4, 2026. What the draft touches is factory building outside China. The SMM analysis says its main implications are for polysilicon, wafer, cell and module plants outside China that rely on Chinese technology, equipment and continuing technical support, and not for solar projects buying equipment.

For a US EPC, that means supply planning for modules and cells from newer non-Chinese factories. The questions are whether those plants reach stable output on schedule and whether their cost reductions continue. Several countries that host such plants, including India, Indonesia, Laos and Ethiopia, are already targets of US trade remedies, through the new orders on India, Indonesia and Laos and the Ethiopia circumvention inquiry. This guide does not say which individual plants rely on controlled technology.

How Long Until This Is Final?

The draft does not say. The consultation ends November 15, and the ministry says the catalogue is adjusted dynamically as technology changes.

There is a precedent. In December 2022, China's commerce and science ministries sought comment on restricting exports of solar wafer technology. By early 2023, press reports said China had banned exports of several wafer and cell technologies, including large silicon, black silicon and cast-mono PERC. That earlier round suggests a draft can become binding within weeks, though the 2026 timetable is not stated.

Exports of controlled technology also have to pass registration in the meantime, so the practical effect begins before the final list does.

Where Design Software Fits

If a module's cell technology or origin changes, the design and the quote change with it: a different cell type, wattage, dimensions and warranty terms move the layout, string design, bill of materials and savings estimate. Design software like Reslink produces the layout, bill of materials and proposal from one 3D design, so a swapped module model flows through the quote instead of being retyped. It cannot tell an EPC where a cell was made or what a final catalogue will say. Supplier documents and the ALMM list do that.

See the full workflow → Book a demo

Frequently Asked Questions

Q1. How can an industry body or manufacturer comment on the draft?

MOFCOM accepts comments between October 16 and November 15, 2026 on the scope of technologies, technical thresholds, control measures and facilitation arrangements. They can be sent by email to jinxianmulu@mofcom.gov.cn, by fax to +86-10-65197565, or by post to the Bureau of Industry, Security, Import and Export Control at the Ministry of Commerce in Beijing. The subject line or cover page should say "Public Consultation on the Catalogue of Technologies Prohibited or Restricted from Export." Submissions made for an organisation must carry its official seal.

Q2. Do the controls affect factories that are already running?

The announcement does not order any plant to stop. The registration rule applies to technology exports that have started but are not complete, so unfinished transfers are caught. The SMM analysis adds that routine after-sales service and normal use of technology already delivered should not be treated as new restricted exports. That is the analyst's reading, not a rule in the announcement, and the final catalogue may say more.

Q3. Does the annex name TOPCon, HJT or PERC?

TOPCon and XBC process technologies appear on the restricted list, as do HJT process technologies, each with thresholds for wafer size, thickness and equipment throughput. Mono-PERC does not appear in the solar annex text read for this guide. The draft does not restrict these cell routes as a whole. It restricts specific processes and the equipment technology behind them, above the stated thresholds.

Q4. Will solar panel prices rise because of the controls?

No source read here quantifies a price effect. The SMM analysis says a rise in module prices is not an automatic consequence and that the effects depend on whether subsequent technology transfers fall inside the final controls. The likelier channel it describes is slower ramp-up and slower cost reduction at newer plants outside China. Treat any specific price forecast as unsupported until the final catalogue is out.

Q5. Is this the same as China's rare earth export controls?

It is a different kind of control. China's 2025 measures covered materials: MOFCOM's Announcement 18 of April 4, 2025 imposed export controls on specific medium and heavy rare earth materials. The 2026 draft covers technology transfers and listed equipment, and the ministry says products made with the listed technologies are not controlled. Both belong to China's wider export control framework, which the ministry says it adjusts over time.

Q6. Where is the official text?

The announcement is MOFCOM and MOST Announcement No. 48 of 2026, dated October 16, 2026, with Annex 1 listing the technologies and Annex 2 the registration form. The ministry also published a spokesperson's answers the same day. This guide read the text through a reproduction and did not open the MOFCOM pages, so confirm any threshold against the official annex before relying on it.

Final takeaway

China's draft export controls on solar technology are confirmed as a draft, with a live registration rule and a closing comment window. What stays open is the final list, its thresholds and its effective date. The scope is also narrower than the phrase "China solar export ban" suggests: it targets technology transfers and listed machines, not finished modules.

For EPCs, the question is supply timing rather than product bans. Watch whether new cell and wafer plants outside China reach stable output, which matters for India's ALMM List-II supply after December 31, 2026 and for the List-III wafer date in 2028. Until the final catalogue is published, treat price forecasts and plant-level claims as unproven.

Sources

Ministry of Commerce and Ministry of Science and Technology of China, Announcement No. 48 of 2026 (October 16, 2026), with Annex 1 and Annex 2, and the MOFCOM spokesperson's answers, as reproduced by Geopolitechs
Shanghai Metals Market, "China Proposes Tighter Solar Technology Export Controls: What Next for the Ex-China Region?" (October 16, 2026), for threshold readings and ramp-up analysis
pv magazine, "China proposes ban on exports of perovskite, tandem solar manufacturing technology" (October 16, 2026)
Global Times, report on the draft catalogue revision (October 16, 2026), for the 14 prohibited and 26 restricted count
PIB, Ministry of New and Renewable Energy, "Government Extends ALMM Framework to Solar Ingots and Wafers" (March 18, 2026)
MNRE ALMM List-II update, as reported by Energetica India (October 2026), for enlisted cell capacity and the December 31, 2026 exemption

This guide summarises a draft Chinese announcement and press reports as of October 17, 2026. The catalogue is not final, and thresholds and dates can change. It is not legal or trade-compliance advice.

#China solar export controls#China solar export ban#solar technology export ban#polysilicon wafer export controls#ALMM List-II#India solar manufacturing

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