On January 14, 2026, President Trump signed a Proclamation under Section 232 addressing national security concerns related to U.S. dependence on foreign semiconductor supply chains. The Administration determined that while the United States consumes approximately one quarter of the world’s semiconductors, it fully manufactures only about 10 percent of the chips it requires. This reliance on foreign production was found to pose a significant economic and national security risk, particularly given the foundational role semiconductors play in national defense, advanced technology, and the broader U.S. economy. However, a disruption to import-reliant supply chains could materially strain U.S. industrial and military capabilities.
Based on these findings, the Secretary of Commerce recommended a two-phase approach to adjusting semiconductor imports. In the first phase, the United States will continue trade negotiations with foreign partners aimed at strengthening domestic semiconductor capacity. As part of this initial phase, the President has imposed an immediate 25% ad valorem tariff on a narrow category of semiconductors, along with certain advanced computing chips such as the NVIDIA H200 and AMD MI325X, and derivative products, when those imports do not contribute to the buildout of the U.S. technology supply chain or strengthening domestic manufacturing capacity. In the second phase, following the conclusion of negotiations, the Administration may recommend and impose broader semiconductor tariffs at significant duty rates, accompanied by a tariff offset program designed to incentivize investment in U.S. semiconductor manufacturing and key parts of the supply chain.
Effective at 12:01 a.m. EST on January 15, 2026, a 25 % ad valorem duty applies to certain defined covered products classified under HTS subheadings 8471.50, 8471.80, and 8473.30, as described in the Proclamation and its Annex. “Semiconductor articles” is defined as imported products that are “a logic integrated circuit, or an article that contains a logic integrated circuit, that meet specified technical parameters, including either a total processing performance greater than 14,000 and less than 17,500 with a total DRAM bandwidth greater than 4,500 GB/s and less than 5,000 GB/s, or a total processing performance greater than 20,800 and less than 21,100 with a total DRAM bandwidth greater than 5,800 GB/s and less than 6,200 GB/s.
The Proclamation provides significant end-use-based exclusions. The 25% tariff does not apply to covered products imported for use in qualifying U.S. data centers, for repairs or replacements performed in the United States, for U.S.-based research and development, for use by U.S. startups, for non-data center consumer applications such as gaming or personal computing, for non-data center civil industrial applications including factory robotics and industrial machinery, for U.S. public sector applications, or for other uses that the Secretary of Commerce determines contribute to strengthening the U.S. technology supply chain or domestic manufacturing capacity for semiconductor derivatives.
The tariff applies regardless of country of origin and is imposed in addition to any other applicable duties, fees, or charges, including AD/CVD, unless expressly excluded. These duties also apply in addition to any preferential treatment from a free trade agreement or preference program. Covered products subject to this Proclamation are not subject to other Section 232 action or to IEEPA Reciprocal Tariffs imposed under Executive Orders 14257, nor to IEEPA Fentanyl Tariffs imposed under Executive Orders 14193 and 14194, although no exemption is provided from IEEPA fentanyl-related tariffs applicable to China. No duty drawback is available for covered products.
Covered products admitted into U.S. foreign trade zones on or after January 15, 2026, must be entered in privileged foreign status. Goods qualifying for Chapter 98 provisions are exempt or partially exempt, as applicable, except that the duties will be assessed on the full value of goods qualifying under 9802.00.60.
Below are the links to the Proclamation, Annex, and further details referenced in this bulletin: