SEMA Comments on Modernization of the African Growth and Opportunity Act

The Solar Energy Manufacturers for America (SEMA) Coalition appreciates the opportunity to submit comments in response to Docket No. USTR-2026-0166 regarding the modernization of the African Growth and Opportunity Act (AGOA). As Congress and the administration consider AGOA’s future, the SEMA Coalition strongly urges USTR to ensure that any modernization of the program safeguards U.S. manufacturing competitiveness, strengthens allied supply chains, and prevents AGOA from becoming a vehicle for third-country tariff circumvention by Chinese-controlled solar supply chains.

As detailed in the following comments, the SEMA Coalition is particularly concerned that AGOA modernization could unintentionally create new pathways for Chinese solar companies to use sub-Saharan African nations as an export platform to circumvent U.S. tariffs, trade remedies, avoid forced labor detection, and possibly avoid new tax restrictions on foreign adversary-controlled supply chains. AGOA should deepen the mutually beneficial U.S.-Africa trade relationships by incentivizing local ownership, technology development, and supply chain development. It should not allow Chinese firms to develop low-end module manufacturing operations, using all Chinese-owned technology and supply chains, that will simply be uprooted after the next antidumping and countervailing duty case is initiated.