TOYO Solar Meeting Notes: Non-China Supply Chain and HJT Roadmap Are Key Focus Areas Amid US Policy Disruptions

Overview

This report contains Goldman Sachs' notes from a virtual meeting with TOYO Solar management, focusing on the US utility-scale solar market, policy changes, industry supply-and-demand trends, and TOYO's technology roadmap. Key discussions include the Section 232 polysilicon investigation, FEOC guidance, AD/CVD investigations, US solar module pricing, US manufacturing capacity ramp-up risks, and TOYO's plan to build HJT cell capacity in Houston.

Core views

The report's core view is that US solar policy may raise imported module prices through minimum import prices and tariff mechanisms, increasing short-term uncertainty but potentially supporting manufacturers with US expansion plans and non-China supply chains. TOYO management believes the company is relatively advantaged in non-China raw material sourcing and manufacturing footprint, while its HJT technology roadmap could provide a competitive foundation for future high-efficiency modules and HJT-perovskite tandem products. At the industry level, current US solar module prices are approximately $0.32/w-$0.35/w, but complex cell manufacturing, labor constraints, interconnection queues, and policy instability continue to limit growth.

Analysis framework

The report primarily uses management interview notes to summarize investment considerations along four themes: policy, supply and demand, costs, and technology roadmap. The policy analysis focuses on Section 232, FEOC, and AD/CVD; the industry analysis focuses on US module pricing, capacity ramp-up, and growth constraints; and the company analysis focuses on TOYO's sourcing, US domestic expansion, and HJT technology roadmap.

Methodology notes

• Company meeting notesSummary of management interview takeaways

  Extracting policy, industry, and corporate strategy implications from management views

  The report does not provide a complete financial model or valuation derivation; instead, it organizes TOYO Solar management's assessments of policy implementation, industry pricing, supply chain risks, and technology roadmaps into meeting notes.

• Factor framework disclosureGS Factor Profile

  Percentile comparisons across Growth, Financial Returns, Multiple, and Integrated metrics

  The disclosure appendix explains that Goldman Sachs compares individual stocks with the market and industry peers using growth, financial returns, valuation multiples, and composite metrics; this section is a methodological disclosure and not a specific score assigned to TOYO in the body of the report.

• M&A framework disclosureM&A Rank

  Assessing the probability of a company becoming an acquisition target on a scale of 1 to 3

  The disclosure appendix explains that Goldman Sachs applies an acquisition-probability framework to covered companies, with 1 representing high probability, 2 medium probability, and 3 low probability; the report does not provide TOYO's specific M&A Rank.

Asset mapping & comparison

Structured mapping from thesis to named assets (strengths, weaknesses, peers, risks).

• TOYO Solar / Toyo Co

  Meeting subject and potentially affected company

  Strengths

  Non-China supply chain positioning, US domestic expansion plans, HJT technology roadmap, and future tandem efficiency pathway.

  Weaknesses

  Capacity still needs to be built; the HJT cell line is expected to begin operations only after 18-20 months, while near-term earnings realization remains subject to policy and project timing.

  Comparison

  Compared with competitors reliant on China-based sources or lacking US expansion plans, TOYO management believes the company has greater compliance and supply chain advantages under the FEOC and AD/CVD environment.

  Risks

  Policy delays or weaker-than-expected implementation, unfavorable AD/CVD investigation outcomes, slow US manufacturing ramp-up, labor and interconnection constraints, and insufficient customer demand.

• US utility-scale solar value chain

  Industry affected by policy and pricing

  Strengths

  Policy may support demand for domestic manufacturing and high-efficiency products, while minimum import price mechanisms could improve the relative competitiveness of US manufacturing.

  Weaknesses

  The industry continues to face labor constraints, interconnection queues, policy instability, and relatively high complexity in cell manufacturing.

  Comparison

  Imported module prices are currently approximately $0.32/w-$0.35/w; if policy raises the minimum import price for modules to approximately $0.55/w, the relative attractiveness of domestic manufacturing could increase.

  Risks

  Policy uncertainty causing project delays, elevated ramp-up risks for new US module capacity, and still limited actual output of high-efficiency/N-type products.

Key data

• Expected minimum import price for wafers$0.20/wManagement's expectation for how Section 232 could be implemented.
• Expected minimum import price for cells$0.30/wManagement's expectation for how Section 232 could be implemented.
• Expected minimum import price for modulesLow to mid $0.40/wExpected minimum import price for modules before additional ad valorem tariffs.
• Imported module price after ad valorem tariffsApproximately $0.55/wManagement expects the Section 232 mechanism could add approximately 25%-30% ad valorem tariffs and replace Section 201 tariffs.
• Current US solar panel price$0.32/w-$0.35/wCurrent US solar panel price range cited by management.
• Houston HJT cell capacity plan1.5 GWTOYO's planned HJT cell capacity.
• Target timeline for HJT capacity start-up18-20 monthsManagement's estimate of the time required for the Houston HJT cell capacity to begin operations.
• Long-term efficiency roadmapApproximately 30% vs approximately 24% currentlyManagement believes that HJT and future HJT-perovskite tandem technology can deliver higher efficiency.
• Goldman Sachs global equity coverage3,074 stocksDisclosure appendix data as of 2026-04-01.

Impact & implications

If Section 232, FEOC, and AD/CVD policies proceed as management expects, US solar import costs and compliance barriers could rise, shifting the competitive focus from low-cost imports toward domestic capacity expansion, non-China supply chains, and high-efficiency technologies. TOYO's potential benefits lie in its non-China sourcing and HJT roadmap, but actual realization will depend on policy implementation, the pace of Houston capacity construction, US manufacturing ramp-up capabilities, and customer demand for high-efficiency products.

Risks

• The final form and timing of Section 232 policy remain uncertain.
• Delays to final FEOC guidance could further postpone project decisions.
• AD/CVD investigations could create additional pressure on import strategies and supply chain arrangements.
• US solar manufacturing expansion faces labor, technical complexity, and ramp-up risks.
• Interconnection queues and policy instability could constrain industry growth.
• Efficiency improvements from HJT and HJT-perovskite tandem technology still require commercial validation.

What to watch

• Whether Section 232 policy is clarified in mid-August as management expects.
• Whether final FEOC guidance is implemented in the middle to late fourth quarter and its impact on project approvals and supply chain qualification.
• Progress in the US Department of Commerce's AD/CVD case involving Ethiopia.
• Progress in construction of TOYO's 1.5 GW Houston HJT cell capacity and the actual start-up date.
• Whether US solar module prices converge toward the policy-implied minimum import price.
• Actual output, customer acceptance, and efficiency improvement pathways for high-efficiency/N-type and HJT products.