In-Depth Analysis of the Monopoly Allegations Against the Photovoltaic Polysilicon Storage and Reserves Platform

Since the end of 2024, China’s photovoltaic industry has been trapped in a severe overcapacity dilemma. Polysilicon prices have continued to fall, corporate profits have deteriorated sharply, and the industry has been forced to launch ‘anti-cutthroat competition’ initiatives, aiming to promote the transformation of the industry from scale expansion to high-quality development [1][2]. Against this backdrop, the China Photovoltaic Industry Association (CPIA) has played a key role, taking the lead in issuing self-discipline initiatives, explicitly resisting chaotic practices such as low-price competition and false quality labeling, and announcing the minimum cost price of modules multiple times [1].

The most controversial measure taken by the industry association is leading the establishment of

(hereinafter referred to as “Guanghe Qiancheng”), marking the official launch of the long-planned “polysilicon capacity integration and acquisition platform” in the photovoltaic industry [1][2]. The platform adopts an innovative “two-pronged” model, implementing a dual-track operation mode of “debt-assuming acquisition + flexible capacity utilization.”

According to data from the National Enterprise Credit Information Publicity System, Guanghe Qiancheng has 10 shareholders, 9 of which are polysilicon-related enterprises. Beijing Zhongguang Tonghe Energy Technology Co., Ltd., a wholly-owned subsidiary of the CPIA, is the 8th largest shareholder with a capital contribution of approximately RMB 100 million and a shareholding ratio of about 3.37% [1][2].

After the establishment of the storage and reserves platform, “whether it constitutes a monopoly” has become the core controversy in the market [1][2]. The controversies mainly focus on the following aspects:

Controversy Focus	Specific Manifestations
Capacity Control	The platform may coordinate production cuts among enterprises and adjust capacity utilization rates
Price Intervention	The industry association has announced the minimum cost price of modules, which has been questioned as price collusion
Market Division	Production and profit distribution may be carried out through capital contribution ratios
Information Coordination	Enterprises conduct communication on sensitive information such as prices, costs, production and sales volumes

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On January 8, 2026, the SAMR held a regulatory interview with the CPIA and six major polysilicon enterprises, including

[1][2]. The meeting notified relevant monopoly risks and put forward clear rectification opinions on antitrust issues.

The regulatory authorities require the involved parties to submit written rectification measures to the SAMR by

, with specific requirements including [1][2]:

Three “Prohibited Acts” Bans:

• Shall not agree on production capacity, capacity utilization rate, production and sales volume, or sales price
• Shall not carry out market division, production distribution, or profit distribution in any form through capital contribution ratios
• Shall not conduct communication and coordination on information such as prices, costs, production and sales volumes

In addition, the regulatory authorities also require:

• The association and enterprises shall effectively establish internal anti-monopoly rules and regulations
• Conduct a comprehensive self-inspection of risks
• Take necessary measures to avoid such situations

Affected by the above news,

[1][2]. Prior to this, due to continuous market rumors, polysilicon futures had risen sharply, and the Guangzhou Futures Exchange (GFEX) had to frequently adjust the trading limits for polysilicon futures. A series of abnormal fluctuations triggered market speculation of “suspected artificial manipulation.”

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According to relevant provisions of the Anti-Monopoly Law [1][2]:

Prohibited Acts	Legal Basis
Monopoly Agreements	Prohibit operators with competitive relations from reaching monopoly agreements
Abuse of Dominant Market Position	Prohibit operators from abusing their dominant market position
Concentration of Operators	Implement pre-event declaration and review for concentration of operators
Illegal Acts by Industry Associations	Prohibit industry associations from organizing operators to eliminate or restrict competition

As early as 2024, Ge Yao, a lawyer from Beijing DHH Law Firm, analyzed that if an industry association, as an “external institution” that is not a party to bidding and tendering, excessively interferes in transactions between subjects in the follow-up, it may be suspected of illegal acts; if it extends its influence further and involves acts prohibited by the Anti-Monopoly Law, such as organizing operators to eliminate or restrict competition, it may be suspected of monopoly acts [1][2].

Industry insiders pointed out that “the bottom line of ‘anti-cutthroat competition’ is strongly related to the Price Law and cannot be crossed” [1]. This means that even well-intentioned industry self-discipline acts cannot violate the basic provisions of the price legal system.

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The core contradiction faced by the current photovoltaic industry is:

Industry Dilemma: Overcapacity → Price Decline → Profit Deterioration → Survival Crisis
    ↓
Response Measures: Storage and Reserves Platform → Capacity Integration → Price Stabilization → Industry Recovery
    ↓
Potential Risks: Monopoly Allegations → Restricted Competition → Distorted Market → Regulatory Intervention

Liu Hanyuan, Chairman of the Board of Directors of Tongwei Group, once emphasized that “anti-cutthroat competition” and “anti-monopoly” are topics faced by the world in different periods. In developing countries, especially current China, the majority of efforts need to prevent excessive competition, disorderly competition and excessive cutthroat competition; while in developed countries where oligopolies have formed relatively clear industries, more attention may be paid to industrial oligopoly [1][2].

• Strictly distinguish the boundary between self-discipline functions and market intervention
• Avoid organizing enterprises to carry out sensitive acts such as price coordination and production distribution
• Strengthen the construction of internal anti-monopoly compliance systems
• Guide enterprises to achieve win-win results through innovation upgrading, quality optimization and service improvement

• Strictly carry out self-discipline in accordance with the requirements of regulatory authorities and competent departments
• Implement the relevant work requirements of the state on “anti-cutthroat competition”
• Timely and truthfully disclose matters that require announcement if any
• Establish an internal anti-monopoly risk self-inspection mechanism

• Strengthen the supervision of product quality
• Strengthen law enforcement on prices and anti-unfair competition
• Severely investigate and punish illegal and irregular acts
• Promote the standardized, healthy and sustainable development of the photovoltaic industry

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Scenario	Probability	Expected Impact
Moderate Capacity Reduction	High	Natural market clearing, gradual elimination of backward production capacity
Administrative Capacity Reduction	Medium	Policy-led capacity integration, which may trigger legal disputes
Market Hard Landing	Low	Large-scale corporate bankruptcies, reshaping of the industry structure

• Pay attention to the follow-up policy trends of regulatory authorities
• Be alert to the risk of price fluctuations in polysilicon futures
• Avoid leading enterprises under monopoly investigation

• Pay attention to changes in the competitive landscape after industry compliance rectification
• Track changes in the market share of leading enterprises
• Evaluate the impact of industry integration on the supply chain

• Pay attention to structural opportunities driven by technological innovation
• Value high-quality production capacity with cost advantages
• Track the progress of overseas market expansion

• Policy Risk
  : Antitrust investigations may interrupt the industry integration process
• Price Risk
  : Changes in market expectations may trigger sharp fluctuations in futures prices
• Compliance Risk
  : Enterprises need to establish a sound anti-monopoly compliance system

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The monopoly allegations against the photovoltaic polysilicon storage and reserves platform reflect the deep-seated dilemma faced by China’s photovoltaic industry during the capacity reduction process: on the one hand, the industry urgently needs to resolve the overcapacity problem through integration; on the other hand, any form of market intervention may trigger legal risks under the framework of the Anti-Monopoly Law.

From a legal perspective,

, and the key lies in:

1. Respect Market Mechanisms
   : Capacity reduction should be market-led, avoiding excessive intervention in market pricing and production distribution by administrative means
2. Operate in Accordance with the Law
   : Industry associations and enterprises shall strictly abide by laws and regulations such as the Anti-Monopoly Law and the Price Law
3. Innovation-Driven Development
   : Achieve sustainable development of the industry through technological innovation, quality improvement and service upgrading, rather than relying on price alliances or capacity coordination

The regulatory authorities’ interview and rectification requirements this time aim to guide the photovoltaic industry to develop healthily on the track of the rule of law, and ultimately achieve the dual goals of

.

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[1] Jiemian News - Photovoltaic “Storage and Reserves” Faces Antitrust Storm, Polysilicon Futures Plunge to Daily Limit (https://m.jiemian.com/article/13860978.html)
[2] Sina Finance - Photovoltaic “Storage and Reserves” Faces Antitrust Storm, Polysilicon Futures Plunge to Daily Limit (https://finance.sina.com.cn/tech/roll/2026-01-08/doc-inhfreqp1194822.shtml)
[3] China Energy News Network - Photovoltaic “Storage and Reserves” Faces Antitrust Storm, Polysilicon Futures Plunge to Daily Limit (https://www.cnenergynews.cn/article/4PsmmN6B6ns)