The White House issued a Section 232 proclamation on January 14, 2026, that imposes targeted tariffs on certain advanced computing chips and establishes a new compliance framework for semiconductor imports. While the initial scope is narrowly defined, the action has immediate implications for classification, end-use documentation, landed cost exposure, and near-term supply network planning. This tariff action is the result of a 2025 Section 232 investigation into the potential risks that importing semiconductors and related goods pose to U.S. national security. The new tariffs take effect on January 15, 2026.
WHAT IMPORT PRODUCTS ARE IMPACTED BY THE SECTION 232 SEMICONDUCTOR TARIFFS?
Covered products include logic integrated circuits and articles containing them that fall within designated HTSUS provisions and exceed the performance parameters established in the annex to the proclamation. Beginning January 15, 2026, a 25 percent ad valorem duty applies to a defined category of advanced semiconductor articles that meet specific technical performance thresholds related to processing capability and memory bandwidth. Applicability is determined by technical specifications rather than product name alone, making product-level review essential prior to entry.
CLICK HERE TO READ THE PROCLAMATION: ADJUSTING IMPORTS OF SEMICONDUCTORS, SEMICONDUCTOR MANUFACTURING EQUIPMENT, AND THEIR DERIVATIVE PRODUCTS INTO THE UNITED STATES
WHAT HTSUS HEADINGS ARE IMPLICATED BY THIS SECTION 232 SEMICONDUCTOR ACTION?
Semiconductor and related product importers should work closely with their trusted Customs brokerage partners to verify compliance across impacted imports. Accurate classification under the Harmonized Tariff Schedule of the United States, combined with correct Chapter 99 reporting and defensible end-use declarations, is necessary to apply the appropriate duty treatment.
Key HTSUS provisions to review include:
- Semiconductor articles subject to the additional duty
9903.79.01 – Semiconductor articles meeting the technical performance parameters defined in U.S. Note 39, subject to an additional 25 percent ad valorem duty
- Base tariff provisions referenced in the annex
8471.50 – Processing units other than those of subheading 8471.41 or 8471.49
8471.80 – Other units of automatic data processing machines
8473.30 – Parts and accessories of machines of heading 8471
- End-use-based exclusions from the additional duty
9903.79.03 – Semiconductor articles for use in U.S. data centers
9903.79.04 – Semiconductor articles for repairs or replacements performed in the United States
9903.79.05 – Semiconductor articles for research and development in the United States
9903.79.06 – Semiconductor articles for use by startups in the United States
9903.79.07 – Semiconductor articles for non-data center consumer electronics applications
9903.79.08 – Semiconductor articles for non-data center civil industrial applications
9903.79.09 – Semiconductor articles for United States public sector applications
Importers should carefully compare product specifications against the technical thresholds outlined in the annex, including processing performance and dynamic random-access memory (DRAM) bandwidth, and confirm end-use to support exclusions and proper duty assessment.
HOW WILL END USE DETERMINE TARIFF APPLICABILITY AT IMPORT?
The additional duty does not apply when covered semiconductor articles are imported for qualifying uses that contribute to strengthening domestic technology capacity or manufacturing capability. Exempted end uses include U.S. data centers, research and development activities, repairs or replacements performed in the United States, startup use, non-data center consumer electronics, non-data center civil industrial applications, and public sector deployments. Importers claiming these exclusions must be prepared to substantiate end use at the time of entry, shifting compliance requirements beyond classification to include documentation, certifications, and cross-functional coordination.
CLICK HERE TO READ THE FACT SHEET: PRESIDENT DONALD J. TRUMP TAKES ACTION ON CERTAIN ADVANCED COMPUTING CHIPS TO PROTECT AMERICA’S ECONOMIC AND NATIONAL SECURITY
WHAT DOES THIS MEAN FOR LANDED COSTS AND SUPPLY NETWORK PLANNING?
For covered products that do not qualify for an exclusion, the additional duty applies in addition to existing customs duties and fees. This introduces landed cost variability tied not only to sourcing decisions, but also to deployment strategy and downstream use. Organizations relying on advanced computing chips should evaluate whether current sourcing and deployment models align with qualifying end uses or whether adjustments to distribution, investment, or manufacturing strategy could mitigate exposure.
The proclamation references continued trade negotiations and monitoring, signaling that broader semiconductor actions may follow—reinforcing the need for longer-term supply network planning considerations.
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