On January 14, 2026, President Donald Trump issued Proclamation 11002, announcing that, effective January 15, 2026, the United States is levying a 25% tariff on “a very narrow category of semiconductors” critical to the artificial intelligence (AI) sector, unless those semiconductors are imported “to support the buildout of the United States supply chain.” The affected semiconductors (also known as semiconductor chips or simply chips) are listed in the Annex appended to Proclamation 11002. This action was taken pursuant to Section 232 of the Trade Expansion Act of 1962, which authorizes the president to adjust duties on goods imported in quantities or under circumstances that threaten U.S. national security following an affirmative finding from a Department of Commerce investigation.
Here, the Department of Commerce initiated its investigation in April 2025 (see Update of April 15, 2025) and, according to the proclamation, transmitted its final report to the President on December 22, 2025. While that report has not been made public, Proclamation 11002 summarizes the Department of Commerce’s conclusions, stating: (1) the Department “found that semiconductors are essential to the United States’ economic, industrial, and military strength,” noting that the country consumes roughly one-quarter of the world’s semiconductors, and (2) “the United States’ capacity to produce semiconductors, certain semiconductor manufacturing equipment such as advanced lithography and etching tools, and their derivative products is insufficient to meet domestic demand,” leaving the country heavily dependent on foreign sources.
Although the 25% tariff is relatively limited in scope, Proclamation 11002 signals potential tariffs on semiconductors, semiconductor manufacturing equipment, and their derivative products. In accordance with the proclamation, the Secretary of Commerce and the United States Trade Representative (USTR) will pursue or continue trade negotiations with countries capable of strengthening the U.S. semiconductor industry and, after those negotiations conclude, recommend a broader tariff “at a rate of duty that is significant.” Still, this broader tariff will be accompanied by a tariff offset program, allowing companies investing in U.S. semiconductor production and certain segments of the U.S. semiconductor supply chain to receive preferential tariff treatment. Proclamation 11002 does not specify when the broader tariff or tariff offset program will be imposed, though the text suggests it may occur within 90 days, when the Secretary of Commerce and the USTR are scheduled to provide their first update on the progress of the trade negotiations, April 14, 2026.
Proclamation 11002 further explains that semiconductors imported “to support the buildout of the United States supply chain” includes chips:
- Used in U.S. data centers;
- Repaired or replaced in the United States;
- Researched and developed in the United States;
- Used by startups in the United States;
- Used for non-data center consumer applications in the United States;
- Used for non-data center civil industrial applications in the United States; and
- Used in United States public sector applications.
The proclamation also notes that any chip listed in the Annex or imported to support the U.S. supply chain “buildout” is exempt from the reciprocal tariff regime implemented under the International Emergency Economic Powers Act (IEEPA), first imposed by President Trump in April 2025 (see Update of April 3, 2025), and from IEEPA tariffs on Canada and Mexico (see Update of February 3, 2025). If a listed chip is already subject to another Section 232 tariff, the tariff imposed by Proclamation 11002 prevails.
