Assessment Report on the Impact of Antitrust Regulation on the Photovoltaic Industry

Based on comprehensive collected information, I hereby provide you with a systematic and professional analysis report.

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On January 6, 2026, the State Administration for Market Regulation (SAMR) held a regulatory talk in Beijing with the China Photovoltaic Industry Association and six leading polysilicon enterprises, including

[1]. The talk notified relevant monopoly risks and put forward clear rectification requirements.

SAMR put forward

[1][2]:

Ban Type	Specific Content
Production Capacity and Price Restriction	Shall not agree on production capacity, capacity utilization rate, production and sales volume, and sales price
Market Division Restriction	Shall not conduct market division, output allocation, or profit distribution based on capital contribution ratio
Information Coordination Restriction	Shall not conduct communication and coordination on information such as price, cost, production and sales volume

• By January 20, 2026
  : The association and enterprises shall submit written rectification measures to SAMR
• Before the completion of rectification
  : All monthly anti-cutthroat competition meetings of the photovoltaic industry convened by the association shall be canceled
• Interim measures
  : All self-disciplinary behaviors related to production restriction and price limitation that have been agreed upon shall be suspended

The regulatory authorities clearly stated that this is a pre-warning, and if antitrust violations still occur in the future, law enforcement cases will be filed for handling[1].

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The photovoltaic industry went through a brutal adjustment period in 2024. According to statistics from S&P Global Ratings and 21st Century Business Herald**[3][4]**, the financial data of six leading photovoltaic module enterprises (JinkoSolar, JA Solar, Trina Solar, LONGi Green Energy, Canadian Solar, Risen Energy) are as follows:

Indicator	Value	YoY Change
Total Operating Revenue	RMB 391.86 billion	-25.71%
Total Net Profit	-RMB 17.807 billion	-163.65%
Average Loss per Enterprise	RMB 2.968 billion	Loss expanded by 1.6 times
Average Interest-bearing Debt	RMB 32.833 billion	-
Average Cash Reserve	RMB 25.8 billion	Interest-bearing debt is higher than cash reserve

[5]:

• Current stock price: USD 21.66, market capitalization: USD 95.31 billion
• Price-to-Earnings (P/E) ratio:
  -11.43x
  (in loss status)
• Return on Equity (ROE):
  -18.28%
• Net profit margin:
  -9.44%
• Current ratio: 1.24, financial status is relatively stable

[4]:

• Net loss of
  RMB 8.618 billion
  in 2024, down 180.15% YoY
• Quarterly losses throughout the year: Q1 - RMB 2.35 billion, Q2 - RMB 2.893 billion, Q3 - RMB 1.261 billion, Q4 - RMB 2.113 billion
• Cash reserve on books: RMB 53.2 billion, interest-bearing debt: RMB 29.8 billion, cash flow is the most stable

[3]:

• Benefited from the tight polysilicon supply period in 2022-2023, with strong profitability in the early stage
• Faced increasing overall downward pressure along with the industry in 2024

According to analysis from Securities Times**[6]**, prices of main industrial chains such as polysilicon have bottomed out and rebounded since July 2025:

• Spot price of polysilicon rebounded from the trough of RMB 35,400/ton to RMB 53,600/ton
• Leading enterprises such as Daqo New Energy and GCL Technology turned profitable first in the third quarter
• The six leading module enterprises recorded a combined loss of RMB 6.004 billion in Q1 2025, with the loss of most enterprises narrowing month-on-month

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Antitrust regulation

[1][2]:

• The polysilicon price increase initiative promoted by the Photovoltaic Association since July 2025 will be suspended
• The silicon wafer price increase (average 12% increase for mainstream N-type silicon wafers) jointly announced by LONGi Green Energy, TCL Zhonghuan, Tongwei Co., Ltd., etc. on December 25, 2025 faces execution risks
• Prices may come under pressure again in the short term
  , and the pace of corporate profit improvement will slow down

Regulation and market-oriented mechanisms work together to promote the exit of backward production capacity:

• The Ministry of Industry and Information Technology clearly stated that it will promote the exit of backward production capacity through
  market-oriented and rule-of-law means
  in 2026[6]
• Improve price monitoring mechanisms and severely crack down on disorderly low-price competition
• It is expected that small and medium-sized high-cost production capacity will be cleared at an accelerated pace

Impact Dimension	Expected Change
Enterprises with Cost Advantages	Will gain greater competitive advantage, and market share is expected to increase
Enterprises with Technological Leadership	Technological innovation will become the core competitive barrier
Enterprises with High Integration Degree	Industrial chain collaboration capability will become a key success factor
Enterprises with Sound Overseas Layout	Avoid domestic price wars and maintain profitability

According to analysis from S&P Global Ratings**[3]**, enterprises with the following characteristics will be the first to weather the cycle:

• High EBITDA margin
  : GCL Technology, Daqo New Energy, Tongwei Co., Ltd., Hengdian DMEGC Magnetics, etc.
• High proportion of overseas sales
  : JA Solar, Canadian Solar, etc., with less impact from domestic price wars
• Diversified revenue structure
  : Some enterprises have additional government subsidies and non-photovoltaic businesses

The “polysilicon production capacity integration and acquisition platform” has been launched, adopting the model of “debt assumption acquisition + flexible use of production capacity”[6]:

• It is expected that the industry will usher in a wave of mergers and acquisitions in the next 1-2 years
• Leading enterprises are expected to increase market concentration through acquisitions

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Lv Jinbiao, a consulting expert of the China Photovoltaic Industry Association, pointed out[6] that

is whether enterprises can adhere to:

• Self-disciplinary production reduction
• Production based on sales
• Not seizing orders at low prices

Antitrust regulation may cause some enterprises to

, especially during the uncertain period before rectification measures are implemented.

The six polysilicon leading enterprises that were summoned account for more than 70% of the national polysilicon production capacity[1]. The regulatory requirement that they shall not conduct market division means:

• Market share competition will become more intense
• Enterprises need to rely on real cost advantages to obtain orders
• Customers’ bargaining power may increase periodically

Scenario	Expected Result
Optimistic Scenario	Effective regulatory implementation + industry self-discipline implemented → orderly production capacity clearance → CR5 increases to over 60%
Neutral Scenario	Market competition-dominated → natural elimination of backward production capacity → CR5 stabilizes at 45-55%
Pessimistic Scenario	Price wars continue + corporate cash flow breaks down → some leading enterprises are merged and integrated

According to analysis from 6Kr**[4]**, technical route risks are diverging:

• TOPCon
  : Current mainstream technical route, with obvious cost-performance advantage
• BC Technology
  : Mainly promoted by LONGi Green Energy, leading in conversion efficiency
• HJT Technology
  : Mainly promoted by Risen Energy, facing the risk of decline, and its performance may further decline in 2025

Overseas markets have become a key battlefield:

• Canadian Solar maintained profitability (RMB 2.247 billion) in 2024 by virtue of its factory layout in the US[4]
• JinkoSolar and JA Solar have a high proportion of overseas sales, with relatively controllable domestic loss pressure
• Trade policies such as the EU Carbon Border Adjustment Mechanism (CBAM) and US anti-circumvention tariffs on Southeast Asia will affect the overseas earnings of enterprises

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Dimension	Assessment
Cost Advantage	Dual leader in polysilicon and cells, with obvious scale advantage
Financial Health	Current ratio of 1.24, relatively stable
Valuation	P/B ratio of 2.18x, at a historical low
Risk	One of the enterprises summoned by regulators, facing short-term compliance pressure
Rating	Prudent Attention , wait for rectification measures to be implemented and profitability to stabilize

Dimension	Assessment
Technological Advantage	Leading in BC technology, with industry-leading conversion efficiency
Financial Health	Cash reserve of RMB 53.2 billion, current ratio of 1.60, the best in the industry
Loss Status	Loss of RMB 8.6 billion in 2024, but the loss narrowed by 32% month-on-month in Q1
Rating	Moderate Attention , cash flow advantage provides a safety margin

Dimension	Assessment
Overseas Layout	High proportion of overseas sales, strong risk resistance
Financial Performance	Loss narrowed by 60.74% month-on-month in Q1 2025
Risk	Asset-liability ratio of 74.74%, interest-bearing debt of RMB 41.4 billion
Rating	Prudent Attention , pay attention to changes in overseas trade policies

Risk Type	Specific Content	Impact Level
Policy Risk	Implementation intensity of antitrust regulation, implementation of rectification measures	★★★★★
Price Risk	Price fluctuations of polysilicon, silicon wafers, and modules	★★★★★
Overcapacity Risk	Industry production capacity clearance pace falls short of expectations	★★★★☆
Debt Risk	Interest-bearing debt is higher than cash reserve, liquidity pressure	★★★★☆
Technological Risk	Asset impairment caused by technical route iteration	★★★☆☆
Trade Risk	Policy changes in overseas markets (EU CBAM, US tariffs)	★★★☆☆

According to the forecast of leading enterprises such as Aiko Solar**[6]**:

• H1 2026
  : The industry will continue to bottom out, with price fluctuations in a range
• H2 2026
  : Expected to see warming signals, with demand gradually recovering
• 2027-2028
  : Enterprises that have completed the transformation to high-quality development will be the first to benefit

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The strengthening of antitrust regulation in the photovoltaic industry is

. It may break the price support brought by the industry’s self-disciplinary mechanism in the short term, but in the medium to long term, it will:

1. Promote market-oriented competition
   : Break price alliances and allow enterprises with real cost and technological advantages to stand out
2. Accelerate production capacity clearance
   : Cooperate with the Ministry of Industry and Information Technology’s policy on backward production capacity exit and compress invalid production capacity
3. Reshape the competition pattern
   : Leading enterprises build moats through technological innovation and efficiency improvement
4. Increase industry concentration
   : The market share of leading enterprises with capital and technological advantages will continue to expand

: Maintain prudence in the short term, focusing on leading enterprises with abundant cash flow, obvious cost advantages, and sound overseas layout; in the medium to long term, lay out core targets with technological leadership and cycle-resistant capabilities on dips.

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[1] Wall Street CN - “All Industry Self-Discipline Promoted by China Photovoltaic Association is Fully Suspended!” (https://wallstreetcn.com/articles/3762868)

[2] Sina Finance - “SAMR Summons 6 Photovoltaic Leaders and Industry Association, Prohibiting Agreements on Production Capacity, Sales Price, etc.” (https://finance.sina.com.cn/roll/2026-01-08/doc-inhfreqi3615743.shtml)

[3] 21st Century Business Herald - “In-Depth | Behind the Data, Which Photovoltaic Module Leader Faces Greater Risks in 2025?” (https://www.21jingji.com/article/20250630/herald/457863f283621d514e13670dc5ecbcf3.html)

[4] 6Kr - “Behind the Data, Which Photovoltaic Module Leader Faces Greater Risks in 2025?” (https://m.36kr.com/p/3357322746698120)

[5] Jinling AI Financial Database - Company Profile and Real-Time Market of Tongwei Co., Ltd. (600438.SS)

[6] Securities Times - “2025 Photovoltaic Industry Battle: From Price Slaughter to Value Reconstruction” (https://www.stcn.com/article/detail/3550235.html)