UFLPA Compliance

1. What the UFLPA Is

The Uyghur Forced Labor Prevention Act (Public Law 117-78) was signed into law on 23 December 2021 and took effect on 21 June 2022. It is enforced by US Customs and Border Protection (CBP) at every port of entry.

The Act creates a rebuttable presumption: any goods mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region (XUAR) of the People’s Republic of China — or by entities on the UFLPA Entity List maintained by the Forced Labor Enforcement Task Force — are presumed to be made with forced labor and are barred from entry into the United States.

The burden of proof rests with the importer. To rebut the presumption, an importer must provide clear and convincing evidence, in the form of complete supply chain documentation, that no portion of the goods was produced using forced labor.

2. Why UFLPA Matters Specifically for Solar

Crystalline-silicon solar panels are uniquely exposed to UFLPA enforcement because polysilicon — the foundational raw material — has historically been concentrated in XUAR. Industry estimates place 35–45% of global polysilicon production in or sourced from Xinjiang as of 2022.

Since UFLPA took effect, CBP has detained hundreds of solar shipments at US ports. Detentions delay projects by weeks or months, trigger lender covenant breaches, and in many cases force importers to re-export or destroy the goods. The reputational and financial cost of a single detention can exceed the value of the cargo many times over.

3. PVMAXX’s UFLPA Position

Polysilicon sourcing

PVMAXX modules are manufactured using polysilicon from verified non-Chinese suppliers in OECD-aligned jurisdictions. Specific supplier identities and quantities are disclosed to qualified buyers under NDA as part of the documentation package.

Manufacturing footprint

All wafer, cell, and module production for PVMAXX-branded panels takes place at Smart Solar Technologies’ facilities in the Republic of Türkiye:

• Aliağa Integrated Plant (Izmir Province) — wafer (1,500 MW), cell (2,200 MW), module (1,200 MW)
• Gebze Module Plant (Kocaeli Province) — module assembly (1,200 MW)

No production step occurs in the People’s Republic of China. No PVMAXX module contains components manufactured in XUAR.

Supplier screening

Smart Solar Technologies operates an ISO 9001-certified quality management system that includes systematic screening of every direct supplier against the UFLPA Entity List maintained by the US Forced Labor Enforcement Task Force, alongside tier-2/tier-3 supplier mapping for high-risk material categories. Detailed screening methodology is shared with qualified buyers under NDA.

4. Documentation Package — What We Provide on Request

PVMAXX provides the following documentation package to qualified buyers under NDA. The package is structured to align with CBP’s UFLPA Operational Guidance for Importers and is suitable for inclusion in lender due-diligence files and CBP detention response submissions.

#	Document	Purpose
1	Polysilicon Origin Attestation	Sworn statement of polysilicon supplier, country of origin, lot numbers
2	Wafer Production Records (Aliağa)	Production batch records linking polysilicon lots to wafer lots
3	Cell Production Records (Aliağa)	Cell line records linking wafer lots to cell lots
4	Module Assembly Records (Aliağa + Gebze)	Final assembly records linking cell lots to finished module serial numbers
5	Bill of Materials with Country of Origin	Component-level BOM with country and supplier per item (encapsulant, glass, frame, junction box, ribbon)
6	Supplier Attestations	Signed UFLPA-compliance statements from each material supplier
7	ISO 9001 Process Documentation	Quality system documentation showing input-traceability controls

5. Alignment with CBP Guidance

PVMAXX’s documentation framework is built to map directly to the requirements set out in:

• CBP UFLPA Operational Guidance for Importers (June 2022)
• DHS Forced Labor Enforcement Task Force Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China (June 2022)
• CBP Solar Industry — Best Practices and Documentation Expectations

Specifically, our documentation provides the tier-by-tier supply chain mapping CBP requests, including: (a) identification of all entities involved in the production of the goods, (b) documentation tracing polysilicon lot through to module serial number, and (c) supplier attestations confirming UFLPA compliance at each tier.

6. How to Request the Documentation Package

Buyers, EPCs, lenders, and insurers can request the full UFLPA documentation package by emailing us@pvmaxx.com with the project reference number and intended use (procurement, financing, insurance, or CBP response). We will return a mutual NDA within 24 hours and the documentation package within 48 hours of NDA execution.

7. Quick FAQ