Polysilicon: Regulation
How forced-labour laws split the solar supply chain
What this tab covers How it is regulated and what could disrupt supply: hazard classification, rules in the EU, US and India, anti-dumping duties and other trade measures, and supply-risk notes.Hazards
| Classification | UN number | Key risks |
|---|---|---|
| polysilicon: not classified; process intermediates trichlorosilane and silicon tetrachloride: flammable, water-reactive, corrosive | not regulated (product); UN1295 trichlorosilane | Chlorosilane fires and HCl releases inside plants. |
Main rules
| Where | Rule | Effect |
|---|---|---|
| US | Uyghur Forced Labor Prevention Act (2022); Section 301 tariffs on Chinese polysilicon and wafers (50% from 2025, indicative) | separates US supply chain from Xinjiang |
| EU | Forced Labour Regulation (applies from December 2027); Net-Zero Industry Act resilience criteria | traceability requirements |
| China | Anti-involution output curbs and draft pricing-law ban on below-cost sales (2025); consolidation company (Dec 2025); mandatory energy-consumption standards for polysilicon from 1 Jan 2027 | aims to retire up to a third of capacity; standards could idle up to 30% |
India
| Rule | Effect |
|---|---|
| ALMM List-III for ingots and wafers: ALMM-listed wafers required for all covered projects, including net metering and open access, from 1 June 2028; list issued once at least three independent makers reach 15 GW combined (MNRE, Mar 2026) | creates domestic wafer demand and, indirectly, polysilicon demand |
| PLI for high-efficiency solar modules (2021, tranche II for integrated poly-to-module plants) | funded integrated projects by Reliance, Adani and others (indicative) |
| Proposed MNRE PLI for polysilicon covering more than 10 GW of capacity (MNRE Secretary, 7 Aug 2026); not yet approved, outlay and terms not disclosed | would support the first Indian polysilicon plants |
| Cabinet decision of 10 Mar 2026 easing FDI from land-border countries for polysilicon and ingot-wafer with a 60-day timeline | allows Chinese technology partners |
Trade measures
- US UFLPA and Section 301
- India BCD on cells and modules and ALMM lists (indicative)
- China's own export of polysilicon technology is restricted (indicative)
Supply risk
China makes over 90% of polysilicon, and Xinjiang-linked supply faces forced-labour bans. Silicon is on India's 2023 critical list. Semiconductor grade depends on a few Western and Japanese firms.