Electronics Products Exempted from “Reciprocal” Tariffs but Could Soon be Subject to Others

A number of electronic products have been exempted from President Trump’s “reciprocal” import tariffs but could soon be subject to Section 232 tariffs instead.

Trump has issued a memorandum stating that the exception from the April 2 reciprocal tariffs for semiconductors applies to products properly classified in the following HTSUS headings and subheadings. Such products include smartphones, laptop computers, semiconductor manufacturing equipment, memory chips, flat panel displays, etc.

– 8471

– 8473.30

– 8486

– 8517.13.00

– 8517.62.00

– 8523.51.00

– 8524

– 8528.52.00

– 8541.10.00

– 8541.21.00

– 8541.29.00

– 8541.30.00

– 8541.49.10

– 8541.49.70

– 8541.49.80

– 8541.49.95

– 8541.51.00

– 8541.59.00

– 8541.90.00

– 8542

This change is effective for covered goods entered or withdrawn from warehouse for consumption on or after 12:01 a.m. EDT on April 5.

U.S. Customs and Border Protection states that for covered products imported since that time filers should take action to correct entries as necessary to reflect this exception as soon as possible within 10 days of the cargo’s release from CBP custody. Importers may request a refund by filing a post-summary correction for unliquidated entries or by filing a protest for entries that have liquidated but where the liquidation is not final because the protest period has not expired.

However, import tariffs on these products are likely to increase again in the near future. According to press reports, the Bureau of Industry and Security is expected to soon initiate a Section 232 investigation of semiconductors (and potentially a broader range of electronics products) that appears likely to result in import tariffs under that national security-related statute. Commerce Secretary Howard Lutnick reportedly said that Section 232 tariffs, contrary to the reciprocal tariffs, are “not available to be negotiated away by countries” but instead are designed to reshore production of affected goods.

Click here to stay up to date on the U.S.’ reciprocal tariffs.

ST&R offers a three-pronged approach to avoiding, mitigating, and/or recovering import tariffs. For more information on which of these strategies might be most effective for your business, please contact ST&R.