A leading PV-module exporter → UFLPA polysilicon traceability + CBAM actual values
US UFLPA demands end-to-end polysilicon traceability while EU CBAM requires actual-value reporting. The group met both with one traceability + PCF platform, optimising tariffs through green-power deductions.
This case is fully anonymised and refers to no specific customer.
- Quartz-sandpolysilicon traceability depth
- −70%less UFLPA response-prep time
- 30–50%potential CBAM savings (actual + green power)
- Multi-marketone filing reused for EU & US
Customer: A PV-module export group (modules to the EU & US, polysilicon from multiple sites)
Background
- Industry
- Photovoltaic
- Solution
- Overseas Compliance
- Customer
- A PV-module export group (modules to the EU & US, polysilicon from multiple sites)
A major global PV-module supplier, with the EU and US as key markets. The US UFLPA applies a “rebuttable presumption” to polysilicon, demanding full traceability from quartz sand to module; EU CBAM, though centred on steel/aluminium/cement, is pushing its methodology and actual-value requirements onto more export categories. The customer’s traceability relied on manual supplier paperwork, falling short of US Customs’ heavy evidentiary bar, and lacked actual-value accounting for CBAM-relevant goods.
The challenge
Under the twin pressure of compliance and cost, these were the core problems.
UFLPA requires polysilicon traceable back to the quartz-sand source; manual ledgers can’t form a continuous evidence chain acceptable to Customs.
Multiple sites and suppliers make batch-to-origin mapping highly complex, raising detention risk.
No capability for CBAM actual values or green-power deductions; default values would inflate potential tariff cost.
The AMT approach
From the data foundation to compliant delivery — phased, end to end.
- 1Full-chain batch traceability
Supply-chain traceability builds batch-level mapping from quartz sand → polysilicon → wafer → cell → module, forming a continuous verifiable evidence chain.
- 2Supplier collaborative reporting
Carbon-Link lets upstream suppliers report traceability and emissions once, reused across markets, cutting repeated back-and-forth.
- 3CBAM actual-value accounting
PCF computes embedded emissions on actual values, adds green-power deductions, and models / optimises tariffs for potential CBAM categories.
- 4UFLPA response pack
One-click export of a traceability evidence pack aligned with US Customs’ logic, shortening detention-response time.
Outcomes
Beyond compliance — quantifiable savings and efficiency.
All figures are anonymised and shown as indicative ranges; they do not refer to any specific customer.
“Every US Customs inquiry used to send the whole company digging through ledgers. Now the traceability evidence is a ready, continuous chain in the platform — responses dropped from weeks to days.”
Shared within NDA limits · anonymised
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