The Section 232 Semiconductor Tariff, Explained

On January 15, 2026, U.S. President Donald Trump issued Proclamation 11002, titled “Adjusting Imports of Semiconductors, Semiconductor Manufacturing Equipment, and Their Derivative Products into the United States.” The proclamation added a new tariff based on Section 232, which gives the president broad powers to implement trade duties. While exact details vary by product, for high-end semiconductors that fall within the scope of this new tariff, a new ad valorem duty rate of 25% has been added.  

What Semiconductor Products Fall In-Scope of This Announcement?  

While there are a litany of tariff exemptions, the full specifications of the products that fall within the scope of this new tariff announcement are available on the Federal Register announcement. Generally speaking, only the highest-end semiconductors and associated assemblies are considered in-scope, including products like Nvidia’s H200 series chips and the AMD Instinct MI325X—both of which are listed by name in the annex of the announcement. Other product series like Nvidia Blackwell (B200/B100) and Intel Gaudi 3 may have specific configurations that will become subject to this new semiconductor tariff.  

What Are the Major Exemptions to the New Tariff?  

Semiconductors being imported into the U.S. for the following reasons are exempted from tariffs under the guidelines published in the Federal Register: 

• Products for use in data centers (defined as facilities using 100MW or more of power) 

• Products for research and development in the U.S.

• Products for use by startups 

• Products for non-data center consumer applications in the U.S. 

• Products for use in non-data center civil industrial applications in the U.S.

• Products that strengthen the U.S. technology supply chain or domestic manufacturing capacity for derivatives of semiconductors.  

• Other exemptions may be added in the future.  

How Should Companies With Exempted Use Cases Respond? 

Companies purchasing semiconductors that have industry-leading performance—often signified by their common use for AI applications—should evaluate the performance capacities of the products they are purchasing to determine if the product is in-scope of the new tariff rate. Manufacturers and distributors of semiconductor products will also be able to advise customers as to whether their products fall within the scope of the new Section 232 tariff. Organizations should also clarify the use cases of their products, to verify that they do, in fact, fit into an exempted use case. Many companies currently utilizing these newly tariffed semiconductor products at scale are exempted from paying the new tariff. 

Finally, companies not directly importing the newly tariffed products should confirm that their distributors are declaring the correct end-use—especially if that intended use-case falls into any of the exempted scenarios outlined above.