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January 15th

Trump administration imposes tariffs on advanced AI chips under Section 232 authority

Date of publication: January 15, 2026
On January 14, the White House announced significant new trade measures targeting advanced computing semiconductors, marking the latest use of Section 232 national security authorities to reshape U.S. trade policy in the technology sector.

Immediate tariff action

President Trump signed a proclamation imposing a 25% ad valorem tariff on certain advanced computing chips, including the NVIDIA H200 and AMD MI325X, effective January 15, 2026 at 12:01 a.m. EST. This represents a narrowly targeted initial phase focused on high-performance AI-enabling semiconductors.

Key exemptions for domestic supply chain development

The tariff includes significant carve-outs and will not apply to chips imported for use in U.S. data centers, repairs or replacements performed domestically, research and development, startups, non-data center consumer applications, non-data center civil industrial applications, U.S. public sector applications, or other uses that the Secretary of Commerce determines contribute to strengthening the U.S. technology supply chain or domestic manufacturing capacity. Further details on the carve-outs can be found in the Proclamation Annex.

National Security Rationale

The action follows a Section 232 investigation by the Commerce Department that identified critical vulnerabilities in U.S. semiconductor supply chains. The investigation found that U.S. capacity to produce semiconductors and certain manufacturing equipment is insufficient to meet domestic demand, leading to dependence on foreign sources.
The United States currently fully manufactures only approximately 10% of the chips it requires, making it heavily reliant on foreign supply chains, which the investigation determined poses significant economic and national security risks.

Two-phase approach

The administration has outlined a phased strategy:
  • Phase 1 (Current)
    : Immediate 25% tariff on a narrow category of advanced AI semiconductors, coupled with ongoing trade negotiations with foreign jurisdictions to strengthen the U.S. semiconductor industry.
  • Phase 2 (Future)
    : Potential broader tariffs on semiconductors and derivative products at significant rates, accompanied by a tariff offset program to incentivize domestic manufacturing. The Commerce Secretary and U.S. Trade Representative must provide an update on negotiations within 90 days.

Trade compliance implications

  • Classification and Administration
    : The Secretary of Commerce, in consultation with the International Trade Commission and U.S. Customs and Border Protection, will determine necessary modifications to the Harmonized Tariff Schedule, end-use certifications, or other administrative measures, to be published in the Federal Register.
  • Interaction with Other Tariffs
    : Covered products subject to this proclamation are not subject to tariffs imposed under reciprocal tariff executive orders or border-related duty measures. This creates a specific carve-out from other concurrent trade actions.
  • No Drawback
    : Duty drawback is explicitly prohibited for tariffs imposed under this proclamation
  • Foreign Trade Zones
    : Products admitted to U.S. foreign trade zones on or after the effective date must be admitted as "privileged foreign status" and remain subject to applicable duties upon entry for consumption

Monitoring and review

The Commerce Secretary will continue monitoring semiconductor imports and must provide an update by July 1, 2026, on the market for semiconductors used in U.S. data centers to inform potential modifications to the tariff regime.

Broader context

The proclamation identifies semiconductors as essential to all sixteen critical infrastructure sectors, including communications, energy, nuclear facilities, and medical systems, as well as modern defense systems requiring high-performance chips for radar, electronic warfare, cybersecurity, and weapons guidance systems.

Action items for trade compliance teams

  1. Immediate
    : Review import classifications for advanced computing chips, particularly NVIDIA H200 and AMD MI325X models
  2. Assess eligibility
    : Determine if imports qualify for exemptions based on end-use (data centers, R&D, repairs, etc.)
  3. Monitor Federal Register
    : Watch for forthcoming Commerce Department guidance on HTSUS modifications and certification requirements.
  4. Prepare for Phase 2
    : Anticipate broader semiconductor tariffs following the 90-day negotiation period.
  5. Review FTZ procedures
    : Ensure compliance with privileged foreign status requirements for affected products.
  6. Update duty calculations
    : Account for non-availability of drawback on these products.
Global trade compliance professionals should closely monitor Federal Register notices from the Commerce Department for detailed implementation guidance, particularly regarding end-use certification procedures and specific HTSUS classifications covered by this action. Review of the CBP CSMS regarding this action should also be done. Additional information can be found in the White House Fact Sheet.
For more information on how ONESOURCE Global Trade solutions can assist you in managing supply chain risk and regulatory compliance as we move into 2026, contact your Account Manager or Client Success Manager.

This article applies to:

  • Product: ONESOURCE Global Trade