5442772026-11-035442772026-11-03ActionsTakenOrOrdersPassedDomain15442772026-11-03ActionsTakenOrOrdersPassedDomain1PersonsAgainstWhomActionsTakenOrOrdersPassedDomain15442772026-11-03SignatoriesDomain1xbrli:pureWAAREEENERWaaree Energies Limited544277NOTLISTEDINE377N01017NewAction(s) taken or orders passed (sub-para 20)false2026-11-0221:35:002026-11-03Any other similar action(s)Review OrderEnforcement AuthorityU.S. Customs and Border Protection, Office of Trade – Regulations and Rulings (Border Security and Trade Compliance Division)1Listed Entity (Self)Waaree Energies LimitedE-MailFinal Administrative Decision dated October 29, 2026 (Ref. OT:RR:BSTC:CVB H363200) in EAPA Consolidated Case No. 8163, issued under 19 U.S.C. § 1517(f) and 19 C.F.R. § 165.45 on the Company’s request for de novo administrative review of the June 23 Determination.2026-11-02The review order received. The review was limited to the one issue raised by the Company: whether a subset of entries originally imported into the United States during 2024 were “covered merchandise” subject to the AD/CVD orders on solar cells from Vietnam, having regard to their time of entry. While RR noted in dicta that the Company had not substantiated that the time of entry of these entries, as determined under 19 C.F.R. § 141.68, preceded the effective dates of the preliminary determinations, it ultimately concluded an entry-by-entry determination of duty liability is not the subject of an EAPA administrative review. On this basis, it affirmed TRLED’s affirmative determination regarding evasion and stated that the appropriate recourse to challenge the assessment of duties on an entry-specific basis is a protest under 19 U.S.C. § 1514 once the evasion determination is complete. The Decision does not expand the scope of the June 23 Determination, which remains limited to a small subset of historical entries. The Decision records that it does not constitute a ruling under 19 C.F.R. Part 177, that it does not preclude CBP or other agencies from pursuing additional enforcement actions or penalties, and that it is subject to judicial review under Section 421 of the Trade Facilitation and Trade Enforcement Act of 2015.Year 2021-2026It has no impact on the Company’s manufacturing operations, business continuity or its ability to serve its customers in the United States or elsewhere. If sustained following the Company’s remaining remedies, the Decision may result in the assessment by CBP of AD/CVD duties, together with interest, at the applicable rates on the limited subset of subject entries covered by the administrative review request, and may require additional customs bonds or cash deposits in the United States. The potential exposure on these entries has been assessed by the Company with its U.S. trade counsel and is already reflected in the Company’s financial statements in accordance with Ind AS 37, and the Decision does not alter that assessment. The matter is not expected to have a material adverse impact on the overall operations or financial position of the Company.Evasion of dutiesNo fine or Penalty is imposedNot applicableThe Decision is not a final adjudication of the matter. The Company is entitled to seek judicial review of the Decision before the U.S. Court of International Trade within thirty (30) U.S. business days of the Decision and independently retains the right to protest any entry-specific assessment of duties under 19 U.S.C. § 1514. The Company, in consultation with its U.S. trade counsel, is evaluating these remedies and intends to take all appropriate steps to protect its interestsRajesh GaurCompany Secretary & Compliance Officer2026-11-03Mumbai