Anza Risk Rating

Our Risk Assessment Methodology

Anza has developed an objective risk assessment methodology for evaluating solar modules. This document details the criteria for the major risk categories that Anza tracks. Our methodology stems from our multi-decade procurement experience and our team’s ongoing assessment of the solar industry and relevant policy. The Anza Risk Rating is not a guarantee, and Anza reserves the right to update the methodology at any time.

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Risk Category

Risk Score

UFLPA Risk

China AD/CVD Risk
_{Includes Anti-Circumvention}

SEA AD/CVD Risk

Counterparty Criteria

Lowest

1 or 2

1 or 2 or 3

Low

3 or 4

N/A

Medium

5 or 6

N/A

3 or 4

High

UFLPA Criteria

In 2022, the U.S. Government’s Uyghur Forced Labor Prevention Act (UFLPA) went into law, operating effectively as an import ban against non compliant materials commonly used in the solar industry. Anza carefully determines a module’s UFLPA Risk per the criteria described below. A low risk indicates a low probability of import seizures and delays thereby lowering the risk of project disruptions and unforeseen costs.

Demonstrated fact pattern of being UFLPA detained and successfully released by U.S. Customs
Ability to Contract and Deliver U.S. assembled Modules and Cells
Manufacturer contractually commits to non- Chinese polysilicon or non-Chinese silicon- metal AND has completed a relevant Third Party Traceability Audit within last two years
Ability to Contract and Deliver U.S. assembled Modules
Manufacturer contractually commits to non-Chinese polysilicon or non-Chinese silicon-metal
Manufacturer’s supply chain is vertically integrated, including at minimum the module’s polysilicon, wafers, ingots, cells and assembly
All other Modules

China AD/CVD Criteria (Includes anti-circumvention)

In response to a petition from a U.S. manufacturer, the U.S. government can impose antidumping (AD) and/or countervailing (CVD) duties on unfair imports that are causing economic harm to the competing U.S. industry. AD cases involve unfair pricing and CVD cases involve foreign government subsidization. The imposition of AD/CVD duties on imports often results in higher prices on the subject imported goods, which often are passed onto Buyers. Anza carefully determines a module’s AD/CVD Risk per the criteria described below:

Modules with Cells manufactured outside of Cambodia, Malaysia, Thailand, Vietnam (except for cells from China or Taiwan, which are subject to their own AD and/or CVD duties)
Modules assembled outside of Cambodia, Malaysia, Thailand, or Vietnam (except for modules assembled from China, which are subject to AD/CVD duties)
Manufacturer has been found to be NOT Circumventing by the U.S. Department of Commerce (DOC) and continues to ensure that it is not circumventing
Manufacturer contractually commits to a bill of materials using non-Chinese Wafers and is required to pay any related AD/CVD duties or cash deposits
Manufacturer contractually commits to bill of material using no more than 2 Chinese components from the below list and is required to pay any related AD/CVD duties or cash deposits. Components: silver paste, aluminum frames, glass, backsheets, ethylene vinyl acetate sheets, and junction boxes
All other Modules

SEA AD/CVD Criteria

In response to new AD/CVD petitions against cells from Cambodia, Malaysia, Thailand, and Vietnam, products which were excluded from the anti-circumvention findings now carry new AD/CVD risk. AD cases involve unfair pricing and CVD cases involve foreign government subsidization. The imposition of AD/CVD duties on imports often results in higher prices on the subject imported goods, which often are passed onto Buyers. Anza carefully determines a module’s AD/CVD Risk per the criteria below:

Modules with cells manufactured outside of the four SouthEast Asian Countries: Cambodia, Malaysia, Thailand, or Vietnam
All other Modules

Counterparty Criteria

Anza has extensive experience buying solar modules in times of varied market pressures. Using the criteria defined below, Anza carefully determines the risk that a manufacturer is going to deliver modules at the contracted price against the possibility of failing to honor the contracted price.

Manufacturer Purchase Order (PO) history with Anza and no failures to deliver at the contracted price in past five years
Manufacturer has U.S., European or Japanese corporate assets (Counterparty to contract or Parent Guarantee to Counterparty) over $50M
Manufacturer failed to honor the contracted price during the Covid Storm*
No PO history with Anza Customers & Affiliates
Manufacturer failed to honor the contracted price within the past five years, excluding the Covid Storm*

_{*Covid Storm is defined as the time period between June 2020 and March 2022 whereby the solar industry experienced unusually high and varied component pricing and supply chain challenges.}

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