U.S. Imposes 25% Tariff on Semiconductors Under Section 232

Trade Update • Jan. 15, 2026

Key Points

• 25% ad valorem tariff on certain advanced semiconductors and derivative products takes effect January 15, 2026.
• The tariff specifically targets advanced computing chips such as NVIDIA H200 and AMD MI325X.
• Tariff applies only to imports not supporting the U.S. technology supply chain or domestic manufacturing.
• Exemptions include U.S. data centers, R&D, startups, repairs, non-data center consumer and industrial applications, and public sector uses.
• The Secretary of Commerce and U.S. Trade Representative will continue trade negotiations to strengthen domestic production.
• In the near future, broader tariffs and a tariff offset program may be implemented to incentivize domestic semiconductor manufacturing.
• CBP issued detailed guidance on entry filing, HTSUS classifications, and exemptions to ensure compliance with the Section 232 tariffs.

On January 14, 2026, President Trump issued a proclamation adjusting imports of semiconductors, semiconductor manufacturing equipment, and derivative products under Section 232. The U.S. has identified that imports of these products threaten national security due to low domestic production and heavy reliance on foreign sources. As a result, the administration imposes a 25% tariff on selected advanced chips, while exempting imports that support U.S. data centers, R&D, startups, and other domestic technology needs. A White House Fact Sheet explicitly mentions that NVIDIA H200 and AMD MI325X are among those subject to the 25% tariff.

25% Tariff Under Section 232

• Effective Date: January 15, 2026
• Covered Products: Advanced computing chips and derivative products, including NVIDIA H200 and AMD MI325X
• Exemptions:
  • U.S. data centers
  • Research & development in the U.S.
  • Startups
  • Non-data center consumer and civil industrial applications
  • U.S. public sector uses
  • Any use contributing to the U.S. tech supply chain

CBP Guidance

CBP issued guidance to support compliance with Section 232 duties on certain semiconductors, semiconductor manufacturing equipment, and derivative products.

Entry Filing Guidance

• Applies to imports entered for consumption or withdrawn from warehouse on or after 12:01 a.m. ET, January 15, 2026.
• HTSUS 9903.79.01: Semiconductor articles meeting specified technical parameters (TPP and DRAM bandwidth) are subject to 25% ad valorem duty.

• • U.S. data centers (>100 MW new load for AI, training, or simulation)
  • Repairs or replacement in the U.S.
  • Research & development in the U.S.
  • Startups (emerging growth companies)
  • Non-data center consumer electronics applications (gaming, PCs, professional visualization, automotive)
  • Non-data center civil industrial applications (factory robotics, industrial machinery)HTSUS 9903.79.02–9903.79.09: Exemptions with 0% duty include:

Exemptions from Other Duties

• Products under 9903.79.01 are not subject to additional duties under certain HTSUS headings for vehicles, copper, aluminum, iron, steel, or specified FTA/import country exemptions (Canada, Mexico, Brazil, India).
• Specific HTSUS headings must be used to declare exemptions from reciprocal, Brazil, or India tariffs.

Drawback and Foreign Trade Zone

• No drawback is available for duties imposed by the proclamation.
• Products admitted to a U.S. Foreign Trade Zone must be “privileged foreign” and subject to applicable duties upon entry for consumption.

Chapter 98 & 99 Provisions

• Entries claimed under Chapter 98 follow normal provisions.
• Chapter 99 duties under the proclamation are assessed in addition to any special tariff treatment or free trade agreement rates.
• Duty exemptions or reductions under Chapter 99 cannot override Section 232 duties.

HTSUS Sequence and Duty Reporting

• Duties must be reported separately for each HTSUS number; do not combine multiple duties on a single line.
• For multiple secondary HTSUS classifications, report in the following sequence:
  1. Chapter 98 (if applicable)
  2. Chapter 99 for additional duties, including Section 301, IEEPA Fentanyl, IEEPA Reciprocal, Section 232/201, replacement duties, and other quotas
  3. Primary classification (Chapter 1–97)

For questions regarding Section 232 entry filing, importers should contact the Trade Remedy Branch at TradeRemedy@cbp.dhs.gov.If any errors occur while filing an entry summary, reach out to your CBP client representative or the ACE Help Desk for assistance.

What Happens Next?

• Secretary of Commerce and U.S. Trade Representative will pursue or continue negotiations to address national security threats.
• Progress updates to the President are required within 90 days.
• Imports will be monitored, and tariffs adjusted if circumstances change.
• By July 1, 2026, an update on data center chips will determine if tariff changes are needed.
• Executive agencies are authorized to implement and enforce the proclamation, including regulations and administrative measures.

How GHY Can Help?

GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.

By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.

Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.