New! On January 14, 2026, President Trump issued a proclamation imposing a 25% tariff on certain defined “semiconductor articles” entered into the US or withdrawn from warehouse into the US. The tariff is effective as of 12:01AM EST January 15, 2026.
Additional details on the tariff are below.
- Exclusions: there are exceptions for products which may be classified in the designated HTSUS provisions, but either do not meet the definition of semiconductor articles, or are used in an excepted circumstance. Goods qualifying for Chapter 98 provisions are exempt or partially exempt, as applicable, except that the duties will be assessed on the full value of goods qualifying under 9802.00.60.
- Stacking: Products subject to these tariffs are exempt from any other Section 232 action and IEEPA Reciprocal and IEEPA Border tariffs (Canada & Mexico). They are not excepted from IEEPA Fentanyl Tariffs (China). The duties apply in addition to any preferential treatment from a free trade agreement or preference program, and in addition to any applicable AD/CVD.
- Drawback: duty drawback is not available for covered products.
- FTZ: covered products admitted after 12:01 am EST January 15, 2026 must be admitted in privileged foreign status.
ST&R offers a three-pronged approach for avoiding, mitigating, and/or recovering these and other tariffs. For more information on which of these strategies might be most effective for your business, please contact ST&R.
Section 232 Investigation
These tariffs result from a Section 232 investigation initiated on April 16, 2025. The investigation assessed the national security risks related to imports of semiconductors and semiconductor manufacturing equipment and their derivative products. The Secretary of Commerce concluded the investigation on December 22, 2025, by transmitting a report with recommendations to the President.
Official Documents