The Department of Commerce’s Bureau of Industry and Security (“BIS”) has initiated a Section 232 investigation of imports of semiconductors and semiconductor manufacturing equipment. According to the Federal Register notice published on April 16, 2025, BIS initiated the investigation on April 1, 2025 to determine the effects on national security of imports of “semiconductors, semiconductor manufacturing equipment, and their derivative products.” BIS asks for public comments by May 7, 2025.
BIS’s notice does not clearly define the specific articles covered by the investigation, but states it “includes, among other things, semiconductor substrates and bare wafers, legacy chips, leading-edge chips, microelectronics, and SME components. Derivative products include downstream products that contain semiconductors, such as those that make up the electronics supply chain.”
This language suggests the investigation and ultimately tariffs could affect a broad range of products and industries. President Trump has imposed 25% Section 232 tariffs on imports of steel, aluminum, certain steel and aluminum derivative products, autos and auto parts, with more expected to hit copper, lumber and pharmaceuticals.
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