U.S. semiconductor and defense supply-chain actions raise the bar for importers and contractors
Date of publication: July 22, 2026.
The Trump Administration has recently linked semiconductors, critical materials, and supply-chain transparency more directly to U.S. national security policy. Two White House actions are especially relevant for companies operating in global trade, electronics, aerospace, defense, advanced manufacturing, and critical infrastructure supply chains.
First, on January 14, 2026, President Trump issued a proclamation under Section 232 of the Trade Expansion Act of 1962 addressing imports of semiconductors, semiconductor manufacturing equipment, and derivative products. The proclamation states that semiconductors are essential to U.S. economic, industrial, and military strength, and imposes a 25% ad valorem duty on certain advanced computing chips and covered derivative products. The proclamation states that the duty will not apply to imports for specified U.S. uses, including U.S data centers, U.S. repairs/replacements, U.S. R&D, startups, non-data center consumer applications, non-data center civil industrial applications, U.S. public sector applications, or other uses the Commerce Secretary determines strengthen the U.S. technology supply chain or domestic manufacturing capability.
Second, on July 20, 2026, President Trump issued an executive order called the "Securing America's Defense Supply Chains and Ensuring Domestic Acquisition of Critical Materials," focused on defense supply chains and domestic acquisition of critical materials. The order directs the Secretary of War (formerly Defense) to develop policy and implementation guidance requiring prime contractors and subcontractors, at any tier, to "map and illuminate" critical supply chains for covered Department of War acquisitions that support, implicate, or relate to U.S. national security. This mapping is expected to cover the chain from raw materials to end-use products delivered to the Department.
Why this matters for global trade teams
These actions signal a continued shift from traditional import compliance toward end-to-end supply chain traceability. Companies may need to demonstrate not only the tariff classification, origin, and value of imported goods, but also the provenance of components, subcomponents, materials, software, suppliers, and upstream inputs. The actions also create potential enforcement exposure if companies provide inaccurate, incomplete, or unsupported supply chain information.
For semiconductor-related imports, companies should review whether products fall within the covered advanced computing chip or derivative-product categories identified in the proclamation and annex. Importers should also assess whether any available exemption or exclusion may apply based on U.S. datacenter, repairs or replacements, research and development, startups, non-data center consumer, or civil industrial applications. Importers should retain documentation supporting any claimed end-use treatment and monitor CBP/Commerce instructions for entry filing requirements.
For defense contractors and suppliers, the July executive order is particularly significant. The forthcoming implementation guidance may require detailed bills of materials, supplier-risk assessments, and controls to identify exposure to restricted or unreliable foreign suppliers. Even companies that do not contract directly with the Department of War may be affected if they supply components, materials, software, electronics, or manufacturing inputs into a covered defense supply chain.
Also, of significance for defense contractors, the Secretary of War will cease issuing routine waivers for covered materials beginning January 1, 2027. After that date, any waiver requires a formal mitigation plan demonstrating exhaustive efforts to source compliant materials and a strict timeline for implementation.
Enforcement and documentation risks
These measures increase the importance of accurate supply chain declarations and defensible compliance controls. For importers, incorrect claims may result in duty assessments or penalties. For defense contractors and suppliers, non-compliance with supply chain mapping requirements may create procurement risk, including potential loss of covered defense contracts.
Companies should take this time to review certification workflows, supplier questionnaires, tariff-exemption analyses, and bill of materials documentation to ensure submissions to government agencies, contractors and customers are accurate, complete, and supported by records.
Companies should consult with counsel on these issues.
Practical next steps
Global trade, procurement, legal, and supply chain teams should consider the following actions:
- Map critical products and suppliers: Identify semiconductor, electronics, critical material, aerospace, defense, and dual-use product lines that may be affected by these actions.
- Review HTS classifications and tariff exposure: Confirm whether imported semiconductor products, equipment, or derivatives are covered by the January 2026 proclamation or related annex.
- Strengthen bill of material visibility: Move beyond first-tier supplier data and begin collecting upstream origin and supplier information for high-risk inputs.
- Screen for restricted supplier risk: Assess exposure to suppliers that may present foreign ownership, control, influence, sanctions, export-control, forced labor, or national security concerns.
- Prepare for customer and government information requests: Defense and advanced manufacturing customers may increasingly request certifications, supply chain maps, origin documentation, and risk mitigation plans.
Outlook
The Administration's recent actions suggest that U.S. trade compliance is becoming more tightly integrated with industrial policy, national security procurement, and enforcement driven supply chain accountability. For companies in semiconductor and defense-adjacent sectors, supply chain transparency is no longer only a resilience exercise - it is becoming a regulatory and commercial requirement.
For more information on how ONESOURCE Global Trade solutions can assist you in managing supply chain risk, tariff challenges, and regulatory compliance, please contact your Account Manager or Customer Success Manager.