25% Section 232 Tariff on Advanced Semiconductors: What Importers Need to Know

Prepared By: Rich Fleischer III, LCB

Issued: March 31, 2026

What This Means for Your Business

If your company imports advanced computing chips used in artificial intelligence workloads, a 25% tariff has been in effect since January 15, 2026. For every $100,000 in customs value of covered semiconductors, $25,000 in additional Section 232 duties is owed. A second round of potential rate changes is now 14 days away.

What Changed

On January 14, 2026, President Trump signed Proclamation 11002, imposing a 25% ad valorem tariff on imports of certain advanced semiconductors and their derivative products. The tariff took effect on January 15, 2026, at 12:01 a.m. Eastern Standard Time.

The authority is Section 232 of the Trade Expansion Act of 1962, the same statute used for the steel, aluminum, copper, and auto tariffs. The administration's national security rationale is that domestic supply chains for the highest-performance computing chips, those central to artificial intelligence infrastructure, are at risk from concentrated foreign production.

This tariff has been in effect for more than two months. With two significant deadlines now approaching, importers who have not reviewed their exposure should do so immediately.

Scope: What This Tariff Covers

The tariff is designed to be narrow. It covers a specific category of advanced logic integrated circuits meeting technical performance parameters defined in the proclamation's annex. In plain terms, these are the highest-end computing chips used in artificial intelligence training, large-scale data processing, and advanced computational workloads, not the chips found in everyday electronics.

General consumer products such as smartphones, standard laptops, tablets, and typical commercial electronics are not within the tariff's scope. The tariff targets the chips at the frontier of performance, those designed for AI infrastructure.

Who Is NOT Affected

The proclamation explicitly excludes from the tariff scope advanced computing chips imported for certain categories of use. These exemptions reflect the administration's intent to impose costs on foreign-source AI supply chains without disrupting domestic consumption or capacity-building. The following uses are exempt from the 25% tariff:

• Use in U.S. data centers

• Repairs or replacements within the United States

• Domestic research and development

• Startups

• Non-data center consumer applications

• Non-data center civil industrial uses

• U.S. public sector applications

• Any other use the Secretary of Commerce determines will strengthen the U.S. technology supply chain or domestic manufacturing capacity

These exemptions are significant. If your business imports advanced chips that fall into one of these categories, consult your customs broker to determine whether your imports qualify for exempt treatment.

The Two-Phase Structure and Upcoming Deadlines

Proclamation 11002 establishes a two-phase approach.

Phase 1 (Current): The 25% tariff is in effect on covered products from all countries, with exemptions as noted above.

Phase 2 (Upcoming): After the conclusion of ongoing trade negotiations, the administration may impose broader tariffs at rates the Secretary characterized as significant, or may reduce exposure for countries that have reached framework agreements.

Two deadlines govern the transition:

July 1, 2026: The Secretary of Commerce must provide the President with an update on the market for semiconductors used in U.S. data centers, which the President may use to modify the current tariff.

Country-of-Origin Considerations

The administration has reached framework agreements with the three countries that collectively account for the majority of advanced semiconductor production. The specific Phase 2 rates are not yet final, but the nature of each country's commitment differs:

Taiwan: Chipmakers committing to substantial U.S. manufacturing investment may import specified quantities with preferential terms.

South Korea: The U.S. has committed to apply Section 232 semiconductor tariff terms to South Korea that are no less favorable than those offered to Taiwan.

Japan: The U.S. has committed to apply to Japan a Section 232 semiconductor tariff rate no greater than that applied to any other country.

These commitments apply to Phase 2 tariff rates only. They do not eliminate the current 25% tariff, which remains in effect for all covered products from all countries. Final Phase 2 terms will follow the April 14, 2026 negotiations report.

Tariff Impact on Costs

The 25% tariff is ad valorem, meaning it applies to the customs value of the imported goods. For every $100,000 in customs value of covered semiconductors, an additional $25,000 in Section 232 duties is owed. This applies to Phase 1 covered imports that do not qualify for an exemption.

Note: Duty drawback is not available for duties collected under this proclamation.

Immediate Action Steps

If your company imports advanced computing chips or products incorporating them:

1. Ask your customs broker whether your semiconductor imports fall within the scope of Proclamation 11002 and whether you owe any unpaid duty from entries made since January 15, 2026.

2. Determine whether your specific use case qualifies for one of the listed exemptions.

3. If you source from Taiwan, South Korea, or Japan, ask your broker to monitor the April 14, 2026 negotiations report for Phase 2 rate announcements.

4. Review your cost structures if you have not yet done so, as this tariff has been in effect since January 15, 2026.

If your imports are standard consumer electronics, commercial electronics, or non-AI-focused computing products, this tariff likely does not apply to your goods. Your broker can confirm.

What to Monitor Next

Three developments could affect your exposure in the coming months.

First, the April 14, 2026 negotiations report will determine the Phase 2 rate structure for Taiwan, South Korea, and Japan. If your supply chain runs through any of those countries, this report may change your duty calculation within weeks.

Second, the final technical specifications defining exactly which products are within scope remain in the proclamation's annex. Classification determinations for borderline products are ongoing. If your chips are near the performance threshold, a formal scope determination may be warranted.

Third, the July 1, 2026 data center market report could trigger a tariff modification that affects the exempt categories listed above.

Your broker should be actively monitoring all three.

Our Commitment

We are monitoring the April 14, 2026 negotiations report and the July 1, 2026 data center market update. We will issue follow-up advisories when Phase 2 terms are announced. If you have questions about whether your specific imports are within the proclamation's scope, contact us at management@fleischer-chb.com or reach out to your Fleischer Group representative directly.

References

Proclamation 11002, Adjusting Imports of Semiconductors, Semiconductor Manufacturing Equipment, and Their Derivative Products Into the United States (January 14, 2026). Establishes the 25% Section 232 tariff on advanced semiconductors effective January 15, 2026.

Federal Register, document 2026-01052 (January 20, 2026). Official Federal Register publication of Proclamation 11002, including annexes defining covered products.

CSMS #67400472, CBP Guidance on Section 232 Import Duties on Semiconductors and Their Derivative Products (January 2026). U.S. Customs and Border Protection guidance on application of the tariff, including exempt use categories.

This trade advisory reflects information available as of the date of publication. Trade regulations, executive orders, and tariff classifications are subject to frequent change. Nothing herein constitutes legal advice. Richard G. Fleischer Customs Brokers encourages all importers to consult with a licensed customs broker or qualified trade counsel regarding their specific circumstances. Published March 31, 2026.