US Polysilicon Stockpiling Controls Are in Force Before December 4 Import Changes

The controls have already started

The BIS temporary rule is effective from September 22 through December 3, ahead of import adjustments scheduled for December 4. It addresses stockpiling of covered polysilicon and derivative products.

Have your broker check the exact tariff classification and product description. Ask the broker to assess the item using its tariff classification and product description.

Importer history affects the review

BIS monitors existing importers for volumes substantially above historical averages. Importers registered on or after August 6 face product-specific weekly limits unless Commerce approves otherwise.

Before moving an order forward, give the broker the proposed quantities and importer details. Ask for a written coverage determination and a review of any applicable volume limit. Keep that response with the shipment approval.

A warehouse arrival may not release the goods

CBP's September 22 guidance says an importer subject to the prohibition may move goods into a bonded warehouse but cannot enter them for consumption before December 4. Affected importers can apply to Commerce for a waiver.

Ask who would carry storage costs and own the delivery risk if your goods could not be released. Include that scenario in the decision to accelerate receipts.

Review the shipment before the price

For any supplier increase attributed to this measure, request the covered tariff line, customs basis and itemized calculation. Review those documents with your broker before accepting the charge.

For production planning, ask the supplier which delivery commitment it can support after the customs review. Record unresolved entry questions against the affected shipment.