Image source: Visual China

Interface News Reporter |

The implementation of the "self-discipline" initiative of the China Photovoltaic Industry Association has made waves again.

On the evening of December 18, the China Photovoltaic Industry Association issued a document angrily criticizing Xinjiang Electric Power Bazhou Power Generation Company for winning the bid for the module project.

The bidding unit is Guodian Power Bazhou Power Generation Company, a subsidiary of the National Energy Group, and the bid-winning candidate quotation of the project is between 0.625-0.631 yuan/W, which is lower than the previous cost price of 0.69 yuan/W given by the association.

China Photovoltaic Industry Association asked the project four questions: whether to strictly implement the requirements of the Central Economic Work Conference? Is the lowest bid excluded in accordance with the relevant provisions of the Bidding Law? Is it the most cost-effective in the whole life cycle according to the relevant requirements of the SASAC and the National Development and Reform Commission? Is it formalism?

According to the association, previously, the bidding unit Guodian Power Bazhou Power Generation Company clearly set a maximum bid limit of 0.6313 yuan/watt in the bidding information. As early as November 18, the association issued a "Risk Warning Letter" to the tendering unit, and suggested that it should not set an unreasonable price limit according to the actual situation. But so far, no response has been received.

Judging from the quotations of the 16 bidders for the above projects announced by the association, 11 are higher than 0.69 yuan/W, most of which are industry leading enterprises, including LONGi Green Energy (601012.SH), TCL Zhonghuan (002129.SZ) Huansheng Photovoltaic, Tongwei (600438.SH), JinkoSolar (688223.SH), Trina Solar (688599.SH), JA Solar (002459.SZ), and GCL Integration (002506.SZ). ), Huayao Optoelectronics, Canadian Solar (688472.SH), Chint New Energy, and a New Energy.

There were five companies with quotations below 0.69 yuan/W, including ReneSola, Seraphim Solar, Gepu Solar, as well as listed companies Hesheng Silicon (603260.SH) and Shanghai Electric Group's Hengxi Solar.

The China Photovoltaic Industry Association believes that in the bidding and quotation of the project, except for a small number of enterprises that are not in the list of "Photovoltaic Manufacturing Industry Standard Conditions" to quote the price within the price limit, the rest of the recognized industry leaders and backbone enterprises are realistic and quote the cost price above the minimum necessary expenses.

"Judging from the recently announced candidates for winning the bid, the bidding unit Guodian Power Bazhou Power Generation Company still insists on choosing the quotation unit within the price limit, and even selects the lowest and second lowest bidders as the winning candidates." China Photovoltaic Industry Association said.

The

two winning candidates for the first bid of the above project are Shanghai Electric Hengxi PV with a unit price of 0.625 yuan/W and ReneSola with a unit price of 0.631 yuan/W. The two candidates for bid 2 are Hesheng Silicon with a price of 0.629 yuan/W and ReneSola Solar at 0.631 yuan/W.

Image source: China Photovoltaic Industry Association

The China Photovoltaic Industry Association questioned: Does the tendering unit, as a subsidiary of the National Energy Group, implement the latest requirements of the central government? Is it to prevent "involutional" competition or to intensify "involutional" competition? Do you regulate the behavior of your own business?

"Let's ask, the maximum price limit of the project is nearly 10% lower than the minimum price we calculated, in the current photovoltaic manufacturing industry has fallen into the whole industry loss, presumably the cost calculation of Guodian Power Bazhou Power Generation Company also has a reasonable legal basis, but the gap is so big, we also want to know what the calculation basis is?" The China Photovoltaic Industry Association asked

The association also proposed that two of the three winning bidders are located in Jiangsu and Zhejiang, and in the case of tax including freight, the fair price of the industry freight is 1.5 cents/watt per 1,000 kilometers, excluding the freight cost of more than 4,000 kilometers, and what is the price of the module itself? Is it below the cost price? Does it meet the requirements of the Bidding Law?

The China Photovoltaic Industry Association requested Guodian Power Bazhou Power Generation Company to answer whether the relevant selection basis is in line with the "best performance-to-price ratio and the best comprehensive cost of the whole life cycle" and "whether it analyzes and judges the abnormally low bids and seriously unbalanced quotations that may be lower than the cost or affect the performance"; At the same time, it is requested that Guodian Power Bazhou Power Generation Company can disclose the relevant basis to the public in accordance with relevant requirements.

As of press time, China Energy Group and Guodian Power Bazhou Power Generation Company have not made any response to the above projects and the questions of the China Photovoltaic Industry Association.

According to the China Photovoltaic Industry Association, in the future, it will continue to pay attention to the procurement information of 290,000 kilowatts of photovoltaic module equipment for the second phase of the 600,000 kilowatt photovoltaic project in the Midong District of Xinjiang Electric Power Urumqi Photovoltaic Company, which also set a maximum bidding limit of 0.6314 yuan/watt.

Although the price of the industrial chain has gradually stabilized, from the price publicity of bidding projects, there are still many enterprises that "ignore" the previous association initiative and offer prices lower than the limit price.

Recently, the bid for "the largest module frame procurement in history" was opened, and the total scale of PV module centralized procurement by PowerChina in 2025 reached 51 GW.

The above-mentioned centralized procurement is divided into three bidding sections, and a total of 58 enterprises participate in the centralized procurement. In the TOPCon module bidding segment, more than one-third of enterprises quoted prices below RMB 0.68/W, with the lowest price being RMB 0.62/W, the highest price being RMB 0.76/W, and the average price being RMB 0.68/W.

In the opening bid price of PowerChina's module framework procurement (bid section 1) disclosed by the association, a total of 19 enterprises quoted higher than 0.69 yuan/watt, and the four leading module companies are listed, and there are still 26 companies with quotations lower than 0.69 yuan/watt, accounting for nearly 60% of the participating bidders.

The China Photovoltaic Industry Association also commented on the article. Liu Yiyang, executive secretary general of the association, said that with the cost reference price of 0.69 yuan/watt announced by the association in November as the red line, the industry leaders and backbone enterprises are all at the upper end, which reflects that in the case of low prices in the photovoltaic industry chain, the leading and backbone enterprises can still maintain the objectivity and rationality of the quotation, and are unwilling to fight the involution type of "price war".

"On the other hand, the enterprises under the red line, not only do not have leaders, but many companies are not in the list of the Ministry of Industry and Information Technology's "Photovoltaic Manufacturing Industry Standard Conditions", and some company names are rarely even heard, and the more unknown enterprises often report lower prices." Liu Yiyang said.

At that time, he also raised several questions, including whether the products of these low-priced bidding companies could withstand such a long time of testing; In the fierce competition of the ups and downs of the photovoltaic industry, whether the enterprise can guarantee long-term operation and provide follow-up warranty services; It is lower than the bidding price of so many leading enterprises, whether it is a super cost control ability or a reduction in product quality requirements.

Liu Yiyang also mentioned that considering that this is a framework procurement, it cannot be ruled out that some companies have the idea of entering the list first through low prices and then "talking" whether they can perform the contract in the future.

Up to now, the project has not announced the winning candidates.

On October 18 this year, in order to prevent involution and malicious competition in the industry, the China Photovoltaic Industry Association gave a module cost price of 0.68 yuan/W, hoping to give the market an authoritative cost data for the reference of the whole industry and government regulatory departments and promote the healthy development of the industry.

In November, the association raised the cost price of modules to RMB 0.69/W after calculation.

After the China Photovoltaic Industry Association spoke, the market once questioned its binding force and role. Previously, a number of relevant people from photovoltaic companies told Jiemian News that they recognized the starting point of the association to maintain healthy competition in the market, but they had doubts about the specific implementation of the price restrictions.

Ge Yao, a lawyer at Beijing Deheng Law Firm, once told Jian News that the industry association, as a self-regulatory organization, conducts self-discipline management of member institutions according to the association's articles of association, but does not have the authority to formulate mandatory minimum cost price data, and the clear "cost" data in the document issued by the photovoltaic industry association is more of a guiding significance.

According to lawyer Ge Yao, there has always been a dispute in practice whether the "individual cost of the enterprise" or the "average cost of society and industry" should be used as the standard for determining the "cost price" of bidders stipulated in the Bidding Law. At present, in the practice of relevant judicial adjudication, the mainstream view is that "individual cost of the enterprise" is the standard for determining the "cost price" of the bidding enterprise. That is, the bidding law does not prevent enterprises from achieving lower prices by improving their own management level and economic efficiency, reducing individual costs. In judicial practice, we respect the individual costs of enterprises, as well as the free and benign bidding of enterprises.

Lawyer Ge Yao said that in the bidding process of enterprises, the tendering party is the subject with supervision authority. When the tenderer's bid evaluation committee finds that the bidder's bid price is significantly lower than other bid prices or is significantly lower than the bid floor when there is a bid floor, it may raise reasonable questions and require the bidder to reasonably explain or provide relevant supporting materials to prove that its bid price is not lower than the cost price. If the proof is improper, the bid evaluation committee of the tendering party may determine that the bid is invalid. After the relevant procurement contract is signed, if there is a dispute over whether the bidding price is lower than the cost price, the parties to the contract may also challenge the validity of the contract and resolve it through judicial means.

The China Photovoltaic Industry Association said in a previous document that if there is a bidding result that violates the "Bidding Law", it will actively explore the possibility of solving the problem through administrative supervision and legal judgment.

Jiemian News contacted China Energy Group on the above bidding matters, but has not received a reply as of press time.