On July 14, 2022, the U.S. Department of Commerce (“Commerce”) issued a request for a range of additional factual information in connection with the agency’s ongoing circumvention inquiries into solar cells and modules from Cambodia, Malaysia, Thailand, and Vietnam that employ inputs from mainland China.[1]  The deadline to respond is July 21st.

In the July 14 memorandum, Commerce seeks information about the:  (1) amount of investment necessary to construct and start-up certain facilities, (2) non-financial barriers (e.g., access to inputs, qualified technical employees, technologies, research and development, etc.) that companies typically face to establish and begin certain operations, and (3) research and development (“R&D”) expenses associated with conducting certain operations.  These types of facilities/operations involved in:

  • refining silicon into solar-grade polysilicon,
  • producing ingots from solar-grade polysilicon,
  • producing wafers from solar-grade ingots,
  • producing solar cells from wafers,
  • producing solar modules from solar cells, and
  • the same operations and products as foreign producers and exporters responding to Commerce’s solar circumvention inquiries. 

The agency is particularly concerned with facilities located, and operations performed, in mainland China, Cambodia, Malaysia, Thailand, or Vietnam, but would accept information pertaining to other countries. 

Commerce is required to consider the level of investment and R&D expenses where circumvention is alleged due to assembly in a third country.  Level of investment and R&D expenses are factors that statutorily must be considered when Commerce assesses whether the processing occurring in Cambodia, Malaysia, Thailand, and Vietnam is “minor or insignificant.”[2]  It is therefore important that interested parties provide Commerce with the requested information by the fast-approaching deadline of July 21st. 

Commerce has requested this information only from “interested parties” in the solar circumvention inquiries which are defined under Commerce’s rules to include foreign producers and U.S. importers, among others.[3] 

Given its depth of experience in international trade and energy issues, Covington is well-positioned to assist clients that wish to respond to Commerce’s request for factual information, or that may have questions more generally about Commerce’s circumvention inquiries.


[1] Crystalline Silicon Photovoltaic Cells, Whether or Not Assembled Into Modules, From the People’s Republic of China:  Initiation of Circumvention Inquiry on the Antidumping Duty and Countervailing Duty Orders, 87 Fed. Reg. 19,071 (Apr. 1, 2022).

[2] 19 U.S.C. § 1677j(b)(2). 

[3] The definition of interested party is provided at 19 U.S.C. § 1677(9) and 19 C.F.R. § 351.102(a)(29).

Photo of Alexander Chinoy Alexander Chinoy

Alexander Chinoy assists clients with the resolution of international intellectual property and trade disputes, appearing before a range of U.S. courts and agencies. He is an accomplished trade litigator who has been involved in more than 30 Section 337 unfair import investigations before…

Alexander Chinoy assists clients with the resolution of international intellectual property and trade disputes, appearing before a range of U.S. courts and agencies. He is an accomplished trade litigator who has been involved in more than 30 Section 337 unfair import investigations before the U.S. International Trade Commission (ITC), as well as a range of enforcement and regulatory matters involving U.S. Customs and Border Protection (CBP) and the U.S. Department of Commerce. Alex has been recognized as a leading Section 337 litigator by Chambers USA, with sources noting he is “impressive beyond his years of practice.”

Alex is a past President of the ITC Trial Lawyers Association, the leading bar association for Section 337 practitioners. He has hands-on experience with every phase of Section 337 investigations. He has participated in a dozen hearings at the ITC ranging from trials on violation to enforcement hearings and temporary relief proceedings. His experience spans every phase of 337 litigation, from pre-complaint counseling through appeal of final ITC determinations to the U.S. Court of Appeals for the Federal Circuit (CAFC), as well as CBP enforcement of ITC exclusion orders.

Alex has additional administrative experience before CBP, including classification and compliance matters, as well as before the U.S. Department of Commerce. His broader litigation experience includes district court intellectual property cases, and a range of trade disputes before the U.S. Court of International Trade. He has successfully argued appeals before the U.S. Court of Appeals for the District of Columbia Circuit and the CAFC. Alex has also counseled foreign governments and multinational companies on the use of trade policy tools to resolve international IPR issues and other business disputes, as well as regarding IPR border measures and enforcement remedies outside the United States.

Photo of W. Andrew Jack W. Andrew Jack

Andrew Jack has a diverse corporate and securities practice with clients principally in the energy, industrial manufacturing, technology and sports and entertainment industries. He regularly represents corporations, board committees, and other forms of enterprises in mergers and acquisitions, strategic alliances, financing activities, securities…

Andrew Jack has a diverse corporate and securities practice with clients principally in the energy, industrial manufacturing, technology and sports and entertainment industries. He regularly represents corporations, board committees, and other forms of enterprises in mergers and acquisitions, strategic alliances, financing activities, securities law compliance, corporate governance counseling, and executive compensation arrangements. Mr. Jack also co-chairs the firm’s Energy Industry Group.

Carol Browner

Carol M. Browner brings nearly four decades of experience advising on environmental and energy policies affecting global energy, environmental, public health, and business matters.

She provides counsel to industry leaders in the energy, transportation, and consumer product sectors on regulatory matters, environmental impact…

Carol M. Browner brings nearly four decades of experience advising on environmental and energy policies affecting global energy, environmental, public health, and business matters.

She provides counsel to industry leaders in the energy, transportation, and consumer product sectors on regulatory matters, environmental impact issues, corporate sustainability approaches, and strategic partnership development to advance clean energy, ESG, and other business priorities.

Carol joins the firm after serving as Senior Counselor in the Sustainability practice of the Albright Stonebridge Group, a global strategy firm.

Carol served as Assistant to President Barack Obama and Director of the White House Office of Energy and Climate Change Policy, where she oversaw the coordination of environmental, energy, climate, transport, and related policy across the U.S. federal government. During her tenure, the White House secured the largest investment ever in clean energy and established the national car policy that included both new automobile fuel efficiency standards and first ever greenhouse gas reduction standards.

Carol is the longest serving Administrator of the Environmental Protection Agency. As Administrator, she adopted the most stringent air pollution standards in U.S. history; set the first fine particle clean air standard; and spearheaded the reauthorization of the Safe Drinking Water Act as well as the Food Quality Protection Act. Carol was known for working with both environmentalists and industry to set science-based public health protections while providing businesses important flexibilities in how to meet those standards. She worked across the agency to ensure a focus on protecting vulnerable populations and promote environmental equity.

Additionally, Carol serves on a number of boards of directors advising on environmental and energy issues, including as Chair of the Board of the League of Conservation Voters, as Chair of the Sustainability Committee of the Board of Directors for Bunge Limited, and as a Board Member of Innovyze.

Photo of Jay Smith Jay Smith

Jay Smith is of counsel in the Washington office. He joined the firm after several years as a professor of political science and international affairs, during which he specialized in international trade policy and international dispute settlement. His practice in the International and…

Jay Smith is of counsel in the Washington office. He joined the firm after several years as a professor of political science and international affairs, during which he specialized in international trade policy and international dispute settlement. His practice in the International and Litigation groups draws on this academic and policy experience.

He is currently helping clients develop and implement strategies with regard to the Trump Administration’s recent trade actions, including pursuing country exemptions and product exclusions to the recent steel and aluminum tariffs imposed under Section 232, and product exclusions to the proposed Section 301 tariffs.

Photo of William Isasi William Isasi

William Isasi has more than 20 years of experience advising governments and companies on all aspects of antidumping and countervailing duty proceedings and World Trade Organization (WTO) litigation. In private practice, he has represented companies in the aircraft, steel, oil and gas, chemical…

William Isasi has more than 20 years of experience advising governments and companies on all aspects of antidumping and countervailing duty proceedings and World Trade Organization (WTO) litigation. In private practice, he has represented companies in the aircraft, steel, oil and gas, chemical, paper, and ball bearing industries, and successfully secured low antidumping and countervailing duty tariffs for his clients. He also advises U.S. companies on the viability of petitioning for antidumping or countervailing duty orders. He joined the firm after serving as an Assistant Chief Counsel at the U.S. Department of Commerce, Office of the Chief Counsel for Trade Enforcement & Compliance. In that role, he provided extensive legal advice on trade enforcement to the Assistant Secretary for Enforcement & Compliance, Deputy Assistant Secretaries, and other Department officials.

Rishi Gupta

Focusing on international trade remedies, trade policy, and appellate litigation, Rishi Gupta has significant experience advising clients that are navigating import restrictions and tariffs such as antidumping/countervailing duties, safeguards, national security tariffs, and exclusion orders. He has handled matters before the U.S. International…

Focusing on international trade remedies, trade policy, and appellate litigation, Rishi Gupta has significant experience advising clients that are navigating import restrictions and tariffs such as antidumping/countervailing duties, safeguards, national security tariffs, and exclusion orders. He has handled matters before the U.S. International Trade Commission, U.S. Department of Commerce, U.S. Customs and Border Protection, and several federal courts. His experience makes him well-positioned to guide clients through high-stakes litigation involving international trade disputes.

Rishi works with clients in various industries, including aerospace, transportation, clean energy, pharmaceutical, technology, and consumer products. Rishi also maintains an active pro bono practice.

Prior to joining the firm, Rishi clerked for the Honorable Jane A. Restani at the U.S. Court of International Trade and the Honorable Evan J. Wallach at the U.S. Court of Appeals for the Federal Circuit.