Some semiconductor subheadings are subject to Section 301 tariffs when the country of origin is China, while others may be excluded or subject to modified rates. The applicability depends on the specific 10-digit HTS classification and the current status of any product exclusions. Importers should verify the Section 301 list status for each subheading and monitor USTR notices for exclusion updates.

CBP generally treats the country where the wafer fabrication (diffusion) occurs as the country of origin for semiconductor devices, as this is considered the substantial transformation step. Subsequent assembly, testing, and packaging in a different country typically do not change the origin. However, the analysis can be fact-specific, and importers with complex multi-country supply chains should consider seeking a CBP binding ruling to confirm origin before entry.