When you price a BOM in 2026, it’s easy to assume semiconductor tariffs now reach every chip on it. However, the Section 232 semiconductor tariff covers only a narrow class of AI accelerator hardware. Ordinary microcontrollers, memory and analog parts keep their existing duty treatment.
That distinction makes a big difference in terms of cost, since most parts in a BOM are subject to other duties outside of Section 232. Critically, duties for specific countries can cost even more than the headline tariff rates. For example, a Chinese-origin microcontroller that’s not impacted by Section 232 still carries a 50% Section 301 duty.
As a result, it’s essential to track the country of origin and gain a comprehensive understanding of what the actual duties are.
This guide shows which Harmonized Tariff Schedule (HTS) headings each duty touches and how to work out exposure line by line.
Key Takeaways
- The 25% Section 232 semiconductor tariff, in force since Jan. 15, 2026, reaches only goods in HTS subheadings 8471.50, 8471.80 or 8473.30 that are, or contain, a logic integrated circuit inside one of two narrow performance bands.[1]
- For most BOM lines, origin drives the cost. Chinese-origin semiconductors pay a 50% Section 301 duty set in the 2024 four-year review.[5]
- U.S. Customs and Border Protection (CBP) rulings generally place origin where the wafer was made, not where the chip was packaged. Advanced packaging can be an exception.[12][13]
What the Semiconductor Tariff Actually Covers
Proclamation 11002 of Jan. 14, 2026 imposed a 25% ad valorem duty on “Covered Products” entered on or after 12:01 a.m. EST on Jan. 15, 2026.[1]
A product must pass two tests together. First, it must be classifiable in subheading 8471.50, 8471.80 or 8473.30. Second, it must be a logic integrated circuit, or contain one, that falls inside one of two performance bands.[1]
Each band pairs a total processing performance (TPP) range with a DRAM bandwidth range. Band one TPP runs above 14,000 and below 17,500 in TPP, with DRAM bandwidth above 4,500 GB/s and below 5,000 GB/s. Band two runs above 20,800 and below 21,100, with DRAM bandwidth above 5,800 GB/s and below 6,200 GB/s.[1]
The proclamation calculates TPP as 2 times MacTOPS times the bit length of the operation, aggregated across all processing units on the chip. DRAM bandwidth includes co-packaged memory such as high-bandwidth memory (HBM) but excludes memory reached remotely over an interconnect.[1]
Because every bound is strict, a part between the bands, below band one or above band two is out of scope. So is a part that meets a processing range but misses the matching bandwidth range.
The proclamation names no chipmakers. The White House fact sheet cited the Nvidia H200 and AMD MI325X as examples of covered chips.[2] But the legal test is the datasheet, not the brand.
The proclamation created nine Chapter 99 headings. CBP guidance confirms that only 9903.79.01 carries the 25% duty. The other eight, including seven end-use exemptions, carry 0%.[1][3]
| Chapter 99 heading | Covers | Additional duty |
|---|---|---|
| 9903.79.01 | Articles inside a performance band | 25% |
| 9903.79.02 | Articles in the three subheadings outside the bands | None |
| 9903.79.03 | Use in U.S. data centers | None |
| 9903.79.04 | Repairs or replacement in the United States | None |
| 9903.79.05 | Research and development in the United States | None |
| 9903.79.06 | Use by U.S. startups (emerging growth companies) | None |
| 9903.79.07 | Non-data-center consumer electronics applications | None |
| 9903.79.08 | Non-data-center civil industrial applications | None |
| 9903.79.09 | U.S. public-sector applications | None |
Read the data center definition before claiming 9903.79.03. A “U.S. data center” must require more than 100 megawatts of new load dedicated to AI inference, training, simulation or synthetic data generation.[1]
Next step: Compare authorized stock and datasheets for HBM3E memory on Findchips
Why Most Chips Fall Outside the Section 232 Tariff
Heading 8542, where integrated circuits are classified, is not among the three covered subheadings.[1] Processors and controllers, memories, amplifiers, other ICs and IC parts all carry a General rate of Free.[4] The three covered subheadings are also Free before the Chapter 99 duty is added.[4]
Falling outside the semiconductor tariff is not the same as duty-free, however. Other duties still apply, and they interact.
- Metals duties: Covered products under 9903.79.01 do not also pay the Section 232 metals duties. Proclamation 11021 renumbered those headings in April 2026 but kept the exclusion.[1][11]
- Forced-labor duties: USTR’s July 2026 forced-labor action under Section 301 exempts 9903.79.01 goods. It also exempts the 8541 and 8542 semiconductor subheadings.[9][10]
- Antidumping and countervailing duties: These still apply on top.[1]
- Reciprocal tariffs: The Supreme Court held on Feb. 20, 2026, that the International Emergency Economic Powers Act does not authorize tariffs. The administration ended collection of those duties days later.[7][8]
Next step: Compare authorized sources and pricing for the LM358 op amp on Findchips
What You Actually Pay: A Worked Example
The table below applies each rate to $16,000 of entered value. For the MCU lines, that is 5,000 pieces at $3.20 each. For line three, it is a fraction of one band-one accelerator board. All figures are illustrative, not quotes from a live BOM.
| Line | Classification | Duty treatment | Duty on $16,000 |
|---|---|---|---|
| 32-bit MCU, Malaysian origin | 8542.31.00.25 | Free; exempt from forced-labor duty | $0 |
| Same MCU, Chinese origin | 8542.31.00.25 + 9903.91.05 | Free + 50% Section 301 | $8,000 |
| AI accelerator board in band one | 8473.30.11 + 9903.79.01 | Free + 25% Section 232 | $4,000 |
The 50% rate comes from the Office of the U.S. Trade Representative’s (USTR) 2024 four-year review of the technology-transfer tariffs on China. It applies to subheading 8542.31.00 under heading 9903.91.05 from Jan. 1, 2025.[5] None of the product exclusions extended through Jan. 9, 2027, covers that subheading.[14]
The arithmetic shows the difference. The semiconductor tariff costs line three $4,000. Sourcing the same MCU from a Chinese fab instead of a Malaysian one costs twice that.
The four-year review reaches diodes, transistors, thyristors, processors, memories, amplifiers, other ICs and IC parts across headings 8541 and 8542.[5] Check your own subheading against U.S. note 31 rather than assuming. Separately, USTR’s December 2025 semiconductor action adds a second Section 301 tariff on Chinese chips. It starts at 0% and rises on June 23, 2027, to a rate USTR will announce at least 30 days earlier.[6]
If a part is exposed on origin rather than classification, the fix is usually an authorized source with a different fab. Comparing distributor stock for a part and its alternates is faster than modeling duty on a source you may not use.
Next step: Compare authorized stock and pricing for the STM32F103C8T6 MCU on Findchips
Country of Origin Usually Follows the Wafer Fab
For semiconductors, origin is not where the part was packaged or labeled. Origin follows substantial transformation, and CBP rulings generally place that at the wafer.
In ruling N326981 of July 26, 2022, CBP reviewed integrated circuits with wafers made in South Korea and back-end work, such as dicing and encapsulation, in China or Taiwan.[12] CBP held that the back-end work did not substantially transform the wafers, so South Korea was the country of origin for marking.[12]
That ruling was issued to one importer for specific goods, and the principle has limits. In ruling H200429 of May 17, 2012, CBP placed origin where wafer-level processing after fabrication took place, not where the wafer was made.[13]
As a result, moving assembly and test to a third country is unlikely to change origin. Moving the wafer fab usually does. Advanced packaging can complicate that, so confirm origin with the supplier before you re-source.
Next step: Compare manufacturers and authorized sources for the GD32F103C8T6 on Findchips
What the Paperwork Requires
Three provisions change how you book the cost of a covered product.
- No drawback: Duties under the proclamation cannot be recovered on re-export.[1][3]
- Foreign-trade zones: Covered products admitted to a foreign-trade zone on or after Jan. 15, 2026, must take privileged foreign status under 19 CFR 146.41. Goods eligible for domestic status under 19 CFR 146.43 are the exception.[1]
- Chapter 98: Chapter 98 claims remain available. However, duties under 9802.00.60 are assessed on the full value of the imported article.[1]
CBP’s July 2026 guidance sets the reporting order on an entry line. Chapter 98 comes first, then Chapter 99 additional-duty headings, with Section 301 ahead of Section 232. The Chapter 1 to 97 classification, which carries the entered value, comes last.[10]
Next step: Search Findchips to confirm the manufacturer and authorized sources for each part on your entry
What Could Change Next
The proclamation recites the Commerce Department’s recommendation of a two-phase approach. Phase one is negotiations with trading partners. Phase two, after those talks conclude, could bring tariffs on semiconductor imports at “a rate of duty that is significant,” along with a tariff offset program for companies investing in U.S. production.[1] The proclamation leaves that step to the president’s discretion.[1]
The commerce secretary was directed to report by July 1, 2026, on the market for data center semiconductors.[1] As of Nov. 11, 2026, no presidential document had amended the proclamation’s rate, scope or nine headings.[16]
Proclamation 11052 of Aug. 6, 2026, adds a 15% duty on polysilicon ingots and polysilicon derivatives from Dec. 4, 2026. It also sets minimum import prices of $21 per kilogram for polysilicon and $100 per kilogram for ingots and wafers.[15]
Next step: Check stock and lead times for DDR4 memory such as the MT40A512M16 on Findchips
Three Questions to Ask of Every BOM Line
Treat semiconductor tariffs as three questions, not one. First, is the part in 8471.50, 8471.80 or 8473.30, and does it fall inside a performance band? Second, what is its country of origin, based on where the wafer was made? Third, which Chapter 99 headings does the entry carry?
For most BOMs, the answer to the first question is no, and the second decides the cost. Re-run all three whenever a part is re-sourced or a phase-two proclamation is issued.
Next step: Compare authorized sources for the parts on your BOM on Findchips
FAQ
Are Semiconductors Exempt From Tariffs?
Not exempt, but most fall outside the Section 232 semiconductor tariff. Integrated circuits under heading 8542 are not covered, and 8542 subheadings carry a General rate of Free.[1][4] Origin-based duties such as Section 301 can still apply.[5]
Is My Part Affected by the 25% Tariff?
Only if it is classifiable in 8471.50, 8471.80 or 8473.30 and is, or contains, a logic integrated circuit inside one of the two performance bands.[1]
Does the 25% Tariff Stack on Other Tariffs?
It is added to most other duties. But covered products do not also pay the Section 232 metals duties or the forced-labor Section 301 duties.[1][9][11] Antidumping and countervailing duties still apply.[1]
Do Tariffs Apply to Semiconductor Manufacturing Equipment?
Not under the current action. The duty applies only to the covered products defined in the proclamation’s annex. The president may consider tariffs on semiconductor manufacturing equipment depending on the outcome of negotiations.[1]
Can I Recover the Duty if I Re-Export?
No. No drawback is available for duties imposed under the proclamation.[1][3]
References
- Proclamation 11002 of Jan. 14, 2026, “Adjusting Imports of Semiconductors, Semiconductor Manufacturing Equipment, and Their Derivative Products Into the United States,” Federal Register Vol. 91, No. 12, pp. 2443 to 2456, Jan. 20, 2026. https://www.govinfo.gov/content/pkg/FR-2026-01-20/pdf/2026-01052.pdf
- “Fact Sheet: President Donald J. Trump Takes Action on Certain Advanced Computing Chips to Protect America’s Economic and National Security,” The White House, Jan. 14, 2026.
- CBP CSMS No. 67400472, “GUIDANCE: Section 232 Import Duties on Semiconductors and Their Derivative Products,” U.S. Customs and Border Protection, Jan. 14, 2026. https://content.govdelivery.com/accounts/USDHSCBP/bulletins/4047318
- Harmonized Tariff Schedule of the United States, 2026 Revision 23, U.S. International Trade Commission, Nov. 10, 2026.
- “Notice of Modification: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation,” Office of the U.S. Trade Representative, Federal Register Vol. 89, No. 181, pp. 76581 to 76614, Sept. 18, 2024.
- “Notice of Action: China’s Acts, Policies, and Practices Related to Targeting of the Semiconductor Industry for Dominance,” Office of the U.S. Trade Representative, Federal Register Vol. 90, No. 245, pp. 60848 to 60850, Dec. 29, 2025. https://www.govinfo.gov/content/pkg/FR-2025-12-29/pdf/2025-23912.pdf
- Learning Resources, Inc. v. Trump, No. 24-1287, Supreme Court of the United States, Feb. 20, 2026. https://www.supremecourt.gov/opinions/25pdf/24-1287_4gcj.pdf
- Executive Order 14389, “Ending Certain Tariff Actions,” Federal Register Vol. 91, No. 37, pp. 9437 to 9439, Feb. 25, 2026. https://www.govinfo.gov/content/pkg/FR-2026-02-25/pdf/2026-03832.pdf
- “Notice of Actions in Section 301 Investigations of Acts, Policies, and Practices of Various Economies Related to the Failure of Each Economy To Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced With Forced Labor,” Office of the U.S. Trade Representative, Federal Register Vol. 91, No. 143, p. 47318, July 28, 2026. https://www.govinfo.gov/content/pkg/FR-2026-07-28/html/2026-15181.htm
- CBP CSMS No. 69326983, “GUIDANCE: Section 301 Forced Labor Import Duties,” U.S. Customs and Border Protection, July 23, 2026. https://content.govdelivery.com/accounts/USDHSCBP/bulletins/421d887
- Proclamation 11021 of April 2, 2026, “Strengthening Actions Taken To Adjust Imports of Aluminum, Steel, and Copper Into the United States,” Federal Register Vol. 91, pp. 18201 to 18266, April 9, 2026.
- CBP ruling N326981, “The country of origin of Integrated Circuits,” U.S. Customs and Border Protection, July 26, 2022.
- CBP ruling H200429, “Country of origin of integrated circuits,” U.S. Customs and Border Protection, May 17, 2012.
- “Notice of Product Exclusion Extensions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation,” Office of the U.S. Trade Representative, Federal Register Vol. 91, No. 216, pp. 72610 to 72611, Nov. 10, 2026. https://www.govinfo.gov/content/pkg/FR-2026-11-10/pdf/2026-22925.pdf
- Proclamation 11052 of Aug. 6, 2026, “Adjusting Imports of Polysilicon and Its Derivatives Into the United States,” Federal Register Vol. 91, No. 153, p. 51975, Aug. 11, 2026.
- Presidential Actions index, The White House, reviewed Nov. 11, 2026.