DBM Commentary: Export Control of Photovoltaic Technology, or an "Open Conspiracy"

2026-10-20 18:05:06

Not too late.

On October 16, the Ministry of Commerce and the Ministry of Science and Technology issued a notice to solicit public opinions on the Catalogue of Technologies Prohibited and Restricted from Export in China, and to implement temporary management measures for pre-export registration of relevant technologies.

The above catalogue shows that five photovoltaic technologies are to be banned from export and seven technologies are to be restricted from export. The 12 technologies cover photovoltaic polysilicon manufacturing, silicon wafer manufacturing and battery manufacturing. In the battery manufacturing process, It involves TOPCon, HJT, xBC and perovskite stack technology (for details, please click Technology Export Control Implementation". As soon as

the above document was released, the interpretation of "photovoltaic export ban" spread rapidly, and the market once worried that photovoltaic going to sea would be blocked. But reading the document carefully, it is not difficult to find that the proposed prohibition and restriction is photovoltaic technology, not photovoltaic products ; And the scope of this control is not all photovoltaic technology , the core is to firmly grasp the cutting-edge technology and key technology in their own hands. It is still open to the technology that has already matured and mass-produced in the industry.

At present, China's photovoltaic industry is experiencing a long and painful industry cycle. Domestic demand slowed down, and the industry became more and more involved. Overseas new production capacity continued to be implemented, and Chinese photovoltaic enterprises were caught in the dilemma of internal and external attacks. The introduction of

technology export control policy will tighten the uncontrolled export of China's advanced photovoltaic technology, lengthen the catch-up cycle of overseas competitors, effectively protect the competitive advantages of domestic enterprises abroad, and win breathing space for the photovoltaic industry at the bottom of the deep cycle. At the same time, it also rewrites the underlying competition logic of China's photovoltaic going to sea.

For a long time, the competition of Chinese photovoltaic products in overseas markets has relied more on "low price" . In the future, with the advantage of intergenerational difference in technology, Chinese photovoltaic products will win more premium.

DBM评论:光伏技术出口管控,或是一场“阳谋”1

Note: This chart has nothing

to do with this article but is specific to the current situation. In the short term, for silicon materials, wafers, cells and

However, it should be noted that the main chain enterprises of overseas factories should conduct self-examination in time, whether the overseas layout involves control technology, and avoid touching the regulatory red line.

For photovoltaic equipment companies , there may be pain in the short term, but it is still good in the long run. After the landing of export technology control, equipment enterprises that have signed bills with overseas enterprises and are performing the contract will face the adjustment of export delivery, which needs to be verified according to the list. Some orders involving control technology may be terminated. However, in the future, domestic equipment enterprises will hold the leading technology, and the voice and bargaining power of overseas markets will continue to improve.

China's photovoltaic industry should be tough.

As we all know, the global photovoltaic industry looks at China. It took more than 20 years for Chinese photovoltaic enterprises to secure their leading position in the global industrial chain. However, in recent years, Chinese photovoltaic enterprises have been in a very passive situation overseas, suffering from the "special treatment" of the United States, India, Europe and other regional countries for a long time, and even forced to start "guerrilla warfare".

In order to survive and open up the market, Chinese photovoltaic enterprises have to go to the local factories, but still bear the local targeted constraints. For example, in the "Big and Beautiful Act" of the United States, "prohibited foreign entities" are clearly defined, and once enterprises are added to these categories, they will no longer be able to enjoy the corresponding preferential policies. Chinese enterprises are one of its key targets.

Such a situation of relying on China's photovoltaic technology while suppressing China's photovoltaic products has long been common in overseas markets. In this regard, there are voices that it is a little late to start export technology control at this time.

I think it's not too late , and the timing is just right.

DBM Comments: PV Technology Export Control, Or an "> At the current global

" At this time, China has introduced measures to control the export of photovoltaic technology, on the one hand, to avoid the outflow of advanced and cutting-edge technology, and to maintain the leading edge of China's photovoltaic industry. At the same time, consolidate China's PV dominance in the world; on the other hand, it may also force part of the market to adjust the suppression of China's PV sector.

For a long time, countries such as the United States and Europe often restrict or even prohibit the import of polysilicon and its derivative photovoltaic products in China for unwarranted reasons. India even relies on ALMM list to implement precise suppression on photovoltaic products such as photovoltaic wafers and batteries in China. At present, the production capacity built overseas is concentrated in the downstream component sector, and there is still a huge gap in the production capacity of upstream silicon materials, silicon wafers and batteries.

In this context, China implements export control for the above-mentioned upstream manufacturing technologies. If overseas manufacturers want to build their own manufacturing lines, they can not bypass the Chinese supply chain, either importing uncontrolled equipment and raw materials from China, or applying for export licenses for restricted technologies and equipment. In this way, some countries will be forced to re-weigh the cost of blocking the upstream links of our country.

More importantly, photovoltaic technology is not only a tool for energy transformation, but also a core strategic resource to support the development of national strategic frontier high-tech industries such as artificial intelligence and aerospace. In response to a reporter's question, a spokesman for the

Ministry of Commerce made clear three considerations, the most important of which is to safeguard national security and interests . "In recent years, the application of photovoltaic technology in sensitive areas such as aerospace, national defense, unmanned equipment and high-security infrastructure has been expanding, and the national security risks that may arise from the export of photovoltaic technology have been rising, so it is necessary to implement timely and appropriate supervision."

In this way, looking at the photovoltaic cutting-edge core technology being included in China's export control catalogue, it seems to be a "restriction", but in fact it is an "open plan"-holding the cutting-edge technology in hand, photovoltaic products are still exported normally, holding reverse game chips, not only a layout for China to regain the voice of the global photovoltaic market. It is also a strategic deployment based on long-term and firm national security and interest barriers.

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On October 13, the Office of Industry and Information Technology of Jiangxi Province announced that due to the revision of the policy of capacity replacement in the cement and glass industry by the Ministry of Industry and Information Technology, the Office of Industry and Information Technology of Jiangxi Province decided to abolish the Rules for the Implementation of Capacity Replacement in the Cement and Glass Industry of Jiangxi Province (Gongxin Regulation No.2024) from the date of issuance of the notice, and to abolish the "Rules for the Implementation of Capacity Replacement in the Cement and Glass Industry of Jiangxi Province". The capacity replacement of cement and glass industry in the whole province will be handled in accordance with the relevant policies of the Ministry of Industry and Information Technology in the future.