How the US Utility Industry Can Navigate Section 301 Tariffs on Imports from China

The U.S. administration has proposed new tariffs and an increase in existing tariffs on key Chinese imports, such as solar cells, EVs, batteries, and critical minerals under Section 301 of the Trade Act. The goal is to bolster domestic manufacturing, promote self-sufficiency in critical sectors and increase supply resilience in the long run.

However, the likelihood of more tariffs on imports from China has created some uncertainties and stress for the utility industry in the United States. The transition to the tariffs can be challenging, especially if utilities face immediate cost and supply pressures for key input materials.

The Office of the U.S. Trade Representative (USTR) is evaluating the public comments on the proposal and is expected to announce the modifications soon.

This makes it imperative for procurement and supply chain leaders in utilities to get a sense of the exact impact these new levies could have on input costs, and what combination of strategies they need to implement to minimize possible disruptions.

How Will New Tariffs Affect Supplies?

These new levies on $18 billion of imports from China are expected to increase the import cost of raw material for battery energy storage systems (BESS), solar photovoltaic components, and steel and aluminum.

However, a close analysis of the expected industrywise impact of the tariffs on cost and supply risks on BESS raw material, solar PV, and steel and aluminum reveals a mixed picture. In some cases, there is likely to be a direct increase in costs, while in some cases, the impact could be minimal, given the current demand and supply dynamics for those goods.

For example, the tariffs may not impact transformer and EV markets as much because be of low import dependence on China.

The proposed increase in solar cell tariffs could also have a minimal effect on U.S. solar installations. However, higher tariff on key raw materials like lithium, cobalt, graphite for battery energy storage systems could strongly hit U.S. battery manufacturers' cost structure and supply chain.

Let’s look at the possible effect of the 301 tariffs on three major markets linked to the utility industry in the U.S.

Steel & Aluminum Market: Low Impact

Section 301 tariffs on Chinese steel and aluminum imports add to the burden of Section 232 tariffs. Now, with a 25% increase, there would be a total tariff of 50% on steel products from August 2024.

However, since the U.S. imports only 1% of its electrical steel from China, the impact of the proposed tariff increases on transformer and EV market and other key consumers of electrical steel will be limited.

Influencing Factors:

• The U.S. imported only 3% of steel from China as of 2023.
• Prices have increased by about 1% for each 1% increase in the tariffs under sections 232 and 301, according to the U.S. International Trade Commission, forcing U.S. importers to bear nearly the full cost of these tariffs.
• Steel prices have fallen by 33% since 2022, except for specialty products. Demand for electrical steel is expected to increase at a faster pace than the other types.
• Proposed U.S. Department of Energy standards to enhance transformer efficiency will limit the availability of imports meeting these efficiency standards.

Solar PV Market: Medium Impact

There is a proposal to increase Section 301 tariff on solar cells from 25% to 50% by 2025. The new tariffs will only have a marginal impact on U.S. solar installations since Chinese solar cells account for less than 1% of U.S. imports. However, there may be a direct impact on solar PV pricing in the near term since bifacial solar panels are no longer tariff-exempt under Sector 201 after the two-year exception recently ended.

Influencing Factors:

• The Uyghur Forced Labor Prevention Act and Antidumping and Countervailing duties have effectively eliminated China as a major source for import of PV modules.
• Chinese manufacturers have already moved cell and module manufacturing to tariff-exempt southeast Asian countries.
• India is poised to become a leading supplier of PV modules in the next few years.
• Cell and wafer production within the U.S. is expected to go up.
• All imported solar panels, including bifacial panels, carry a tariff of 14.25% after a two-year exemption.
• The tariff rate quota of silicon solar cells could also be increased by 7.5 GW to 12.5 GW.

BESS Market (Non-EV Batteries): High Impact

The imposition of a 25% tariff on key raw materials for BESS (non-EV batteries) will have a notable impact on the cost structure and supply chain for U.S. battery manufacturers. The tariff implementation is proposed for 2026. The raw materials imported from China include lithium, cobalt, graphite and manganese.

Influencing Factors:

• Existing tariffs on key raw materials for domestic battery production will continue to put pricing pressure on local manufacturers.
• Highest-risk rare earth minerals are lithium, graphite and cobalt.
• BESS installations are expected to go up through 2025.
• 52 new plants are set for construction through 2026.

What Should Supply Chain Leaders at Utilities Do to Navigate Section 301 Tariffs?

Do Forward Planning

• Establish a three-to-five-year sourcing plan to allow time for strategic procurement of at-risk equipment.
• Utilize the sourcing plan to establish alliance partnerships with suppliers, lock in production slots for long-lead-time materials and evaluate risk areas and new technologies.
• Include contractual language in agreements that specify component production locations and pricing adjustment mechanisms.

Be Flexible

• Build flexibility into project timelines and specifications or equipment designs to improve sourcing efficiency and accommodate potential delays in sourcing materials or production.
• Frequently reassess business needs, identify any required changes to the sourcing plan, and proactively work with suppliers to mitigate any project risks.

Engage With Regulatory Bodies and Industry Consortiums

• Work with regulatory bodies to develop supportive policies and frameworks that mitigate the financial impact of tariffs.
• Join industry consortiums and alliances to collectively address supply chain challenges and negotiate better terms with suppliers.

Staying Prepared

The proposed Section 301 tariff changes represent a strategic shift aimed at securing supply chains and spurring investments in domestic manufacturing facilities and technologies.

While public comments on the proposal for new tariffs are being evaluated, chief procurement officers and chief supply chain officers are advised to start the process to assess challenges posed by the tariffs and employ a combination of strategies to cushion their impact. These approaches should not only help mitigate immediate financial impacts but also foster a more resilient and adaptable supply chain for utilities in the face of trade uncertainties.

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