We source PV modules and other energy renewables from China and other parts of the world, for sale in the USA. We're considering adding a certain amount of US content to products we import. From practical experience, what does it take typically to comply with "Made in America" requirements for federal or state projects for PV panels?

Gary - gstewart@VerdeGen.com

First, 50% of the component value must be "buy America" qualified.
Next, the final assembly must be in the US.
The final assembly must "substantially alter" the product.
I believe that anything from NAFTA countries qualifies as "buy America."
The commerce department makes the rules on the meaning of "substantially alter" on a case by case basis. Their interpretation is rather (unbelievably) stringent. A major home improvement chain exported US made metal blanks overseas for machining. After machining, the parts came back, were rounded, finished, had the head angle modified (bent), and the handle covered with a rubber sheath. Commerce said that all the finishing, modification of the shape, and covering the handle did not qualify as "substantial transformation" for the hammers.

My interpretation is that attaching a frame and placing a junction box probably is not sufficient. My guess is that laminating, framing, and final wiring of a PV panel would be required to pass muster. But changing a panel to attach an inverter or a unique mounting system just might do the trick.

Note: I am not a lawyer, this is just what I've picked up from research last year. Be sure to use legal counsel with commerce department and import experience. Interpretations of statutes can change over some pretty short periods too.

Feel free to send info on your panels and other components used in PV installations. I work closely with developers all over the place and could put in a good word for a great product offered by great guys like you!

Bill,

Thanks for the helpful comments. We'll definitely take them into account as we think about if/how to produce panels here. Somewhere along the way I can imagine a lawyer making some money off us as we deliberate!

Regarding your info request, VerdeGen (my company) and SOLARBROKER (my German partner's company) work together to source PV panels from Asia, mostly China. Their site is www.solarbroker.net where their services are detailed. One of the interesting aspects of our joint services is the on-site QA inspections that are done on the actual panels as they are produced. This gives our clients both low-cost (volume-based, factory-direct) and high-quality panels. If you come across anyone that we might help, let me know!

Cheers,
Gary

Dear Gary,


I would suggest to contact the chamber of commerce.
I'm not sure about the rules and regulations regarding country of origin in the United States as I'm from the Netherlands but I do know that there are ways to do this.

It's basically what Bill was saying previously. There has to be a assembly process in the USA. Most likely the chamber of commerce, which is (in the Netherlands) allowed to provide a certificate of origin, will be visiting your company to see if this is significant enough and there has to be a significant difference between the product received at your warehouse and the final product shipped to your customers.
For example, props of a vessel are usually pre fabrcated ( solid steel without any fittings etcetera). The final assembly would be to drill holes for mounting it to the specific vessel and so on. This usually is enough to make it the country of origin.

I understand this is more difficult for pv panels but, like Bill said, you could sell your complete system as being 1 product. This allows you to import different components such as pv panels, inverters, trackers and assemble them and then sell them as a single product.

Please do let me know if. You need any further help.
I'm interested in the USA market and our company is searching for pv panel manufacturers and we where thinking Bout sourcing them from the USA so it won't be bad for myself to do some research about the USA rules and regulations.


Best Regards,


Ron Westerhof

Hi Ron,

I hadn't thought about Chambers of Commerce as an avenue, both for federal level and state level projects. I'll check on it.

The very clear message in all of this is: the more US components, US labor and US value-added... the better.

Best Regards,
Gary