The Office of the United States Trade Representative (USTR) has issued afinal action under Section 301 of the Trade Act of 1974 regarding China’s acts, policies, and practices aimed at dominating the semiconductor industry. USTR determined that these practices are unreasonable and burden or restrict U.S. commerce, making them actionable under U.S. trade law.
The Key points of the action are:
- Tariff action on semiconductors from China will be implemented, although the initial tariff rate is set at 0 percent. This tariff level is scheduled to increase on June 23, 2027 with the specific rate to be announced at least 30 days before that date
- The action modifies the Harmonized Tariff Schedule of the United States (HTSUS) to impose additional duties on certain Chinese semiconductor products as listed in the USTR annex
- This responsive action takes effect on December 23, 2025
- You can view the FRN here
The underlying Section 301 investigation was initiated in late 2024 to assess whether China’s policies relating to its semiconductor industry—which includes semiconductors and related supply chain products used in critical sectors such as defense, automotive, medical devices, aerospace, telecommunications, and power infrastructure—constitute unreasonable or discriminatory practices warranting trade remedies. We’re including an overview of the affected HTS below:
What this means for importers:
- While tariffs are initially set at 0 percent, the planned rate increase in mid-2027 could impact the cost basis for imports of covered semiconductor products from China
- Affected companies should monitor future Federal Register notices announcing the tariff rate increase and consider potential supply chain, sourcing, and duty planning implications
Alba offers guidance and support for the semiconductor and electronics industry – talk with us about:
- HTS & Compliance Check: We can validate your current product classifications to ensure you’re benefiting from the lowest landed cost calculations
- Post Summary Corrections: If we identify misclassifications, we can investigate and file PSCs as appropriate
- Forward Policy Monitoring: We will continue to monitor trade and regulatory updates, and provide you with additional alerts so you can stay ahead of shifts
Please contact us at TradeServicesRequests@albawheelsup.com and we can discuss your specific circumstances.
