Section 232 Tariffs Possible on Imports of Semiconductors, Pharmaceuticals

The Bureau of Industry and Security is accepting input no later than May 7 on two new Section 232 investigations it has initiated on semiconductors and pharmaceuticals. Given comments from Trump administration officials, these investigations seem likely to result in the imposition of additional tariffs on imports of these products within a fairly short time.

Products covered by these investigations include the following.

– semiconductors and semiconductor manufacturing equipment, including semiconductor substrates and bare wafers, legacy chips, leading-edge chips, microelectronics, and SME components, as well as derivative products, which include downstream products that contain semiconductors, such as those that make up the electronics supply chain

– pharmaceuticals and pharmaceutical ingredients, including finished generic and non-generic drug products, medical countermeasures, critical inputs such as active pharmaceutical ingredients and key starting materials, and derivative products of those items

Interested parties are invited to submit written comments, data, analyses, or other information pertinent to these investigations. Among other things, BIS is interested in (1) current and projected demand for covered goods, (2) the extent to which domestic production can meet that demand, (3) the role of foreign production or supply chains in meeting that demand, (4) the concentration of U.S. imports from a small number of suppliers and the associated risks, (5) the impact of foreign government subsidies and predatory trade practices on U.S. industry competitiveness, (6) the economic or financial impact of artificially suppressed prices due to foreign unfair trade practices and state-sponsored overcapacity, (7) the potential for export restrictions by foreign nations, (8) the feasibility of increasing domestic capacity to reduce import reliance, and (9) the impact of current trade and other policies on domestic production and whether additional measures, including tariffs or quotas, are necessary to protect national security.