Beyond this median figure, there has been little variation in the price of such modules, with the interquartile range of prices of modules assembled in the US, representing the middle 50% of the Anza dataset, falling between US$0.28/W and US$0.325/W.

This stability is a welcome change to a number of other financial metrics in the US solar sector, which have been disrupted by an “extremely dynamic” policy landscape, according to analyst LevelTen Energy, whose power purchase agreement (PPA) figures show significant disruption in US solar. Specifically, the average price of a solar PPA signed in the US fell by 4.8% in the second quarter of this year, reversing a trend of sustained quarter-on-quarter price increases that had held steady for two years.

“Minimum prices have been steady,” notes Mike Hall, CEO of Anza, speaking to PV Tech Premium this week about Anza’s latest module price figures. However, rather than suggesting that this stability is reflective of a move away from the kind of disruption and uncertainty that has affected the US solar sector under the second Trump administration, he argues that the industry is in something of a “wait-and-see” mindset.

“Generally we’re in a bit of a wait-and-see period with pricing as buyers and sellers are waiting to see what will happen with 232 Tariffs on polysilicon and derivative products,” he explains, pointing to the investigation of polysilicon imports on the grounds that they pose a national security threat under the Section 232 legislation, which has created more questions than answers for US solar.

Hall adds that even within the relatively stable ‘wait-and-see’ environment for US module assembly, there are variations in module prices.

“We have seen some specific categories of modules increase in price faster,” he explains, pointing to ongoing patent disputes in the industry that have affected specific module technologies. “Not surprisingly, imported passivated emitter rear contact (PERC) modules have increased in price as there are concerns about risk to tunnel oxide passivated contact (TOPCon) imports from First Solar’s 337 IP case.”

“We have also seen any products with US polysilicon increase significantly in price over the last 90 days,” he continues. “We believe this is due to concerns around 232, and customers willing to pay extra for protection. Lastly, we’ve seen slight increases in prices from products that are able to provide high-quality foreign entity of concern (FEOC) compliance certification.”

FEOC concerns continue to affect the US solar industry, with the designation of China as a FEOC particularly impactful; not only is China responsible for the vast majority of material, component and product manufacturing in the global solar industry, but a number of Chinese companies have sought to build manufacturing capacity in other countries to facilitate trade with the US. While the imposition of FEOC restrictions could encourage developers in the US to look to source components from domestic manufacturers, Hall argues that the implementation of these rules has created confusion.

“There are still many obstacles, and I don’t think the FEOC guidelines have been terribly helpful for US manufacturers,” he explains. “The 45X tax credits and the investment tax credit (ITC) adders drove all of the domestic manufacturing momentum. The FEOC rules, and lack of sufficient guidance, have been a headwind for many domestic manufacturing projects that have to deal with concerns about both ownership and influence from foreign entities of concern.”

The complexity in the US manufacturing space is perhaps best exemplified by Anza’s own terminology for its figures: its latest report tracks modules that are “assembled” in the US, rather than “manufactured”, and Hall explains that the company has had to begin explicit tracking of modules that use components made overseas, and assembled in the US, to achieve a status that he calls “domestic lite”.

“We started tracking US assembled modules as we’ve seen an increasing number of developers employ what we call a ‘domestic lite’ model to obtain the domestic content ITC adder,” he says, in reference to the tax credit that is an essential facilitator of clean energy manufacturing in the US.

“In some cases it’s possible for projects to get enough domestic content points without having a US-made cell. It’s not easy, but it can be done,” he continues. “The interest from customers in this strategy led us to launch US-assembled modules—with imported cells—as a category.”

While Anza’s figures suggest that the majority of modules assembled in the US comply with FEOC restrictions—in July, 32 of 55 module assemblers were shown to be FEOC-compliant, according to Anza—this uncertainty in the broader supply chain environment will do little to support an industry that, as Hall notes, is still at a cost disadvantage compared to China.

“US demand is robust, and there are a number of risk and financial incentives driving customers to want to buy domestic,” he says. “However the US is still at a cost disadvantage to China and other lower cost producing countries. Therefore tariffs on materials and components are a risk to domestic manufacturers.”

When asked about the future policy environment for US solar, Hall was pessimistic that things could change for the better, or at least for the more stable, for the industry.

“We don’t have reason to believe that the policy and trade landscape will be more stable the rest of the year,” says Hall. “We’re still waiting to hear from the government on 232, and the First Solar IP case will continue for some time. In addition, the administration continues to announce new tariffs—not specific to solar—so I believe there is still concern in the market that there could be more surprises to come.”

While the current administration’s penchant for unpredictability and hostile market activities is not a surprise per se—upon the passage of the ‘One Big, Beautiful Bill’ last year, the Union of Concerned Scientists said that the House had “done its level best to engineer an energy crisis”—Hall argues that the recent behaviour of the administration has done little to engender confidence within the US solar sector.

He points to the anti-dumping and countervailing duty (AD/CVD) petitions in particular—which this month targeted Toyo Solar and its cell production in Ethiopia—as an example of these hostile market activities that have set a precedent for an uncomfortable policy landscape for US solar.

“Every petition has been successful,” says Hall. “At this point, it’s reasonable to predict that any country having success producing and importing into the US will eventually get caught up in AD/CVD investigations and likely be subject to duties.”