Semiconductor recording media from China have been subject to Section 301 tariff measures, though the applicable list and any exclusions depend on the specific HTS subheading. Given the complexity of exclusion orders and their expiration dates, importers should verify current Section 301 exposure for each product type with a licensed customs broker.

CBP applies the substantial-transformation test. For flash memory products, the country where the NAND die is fabricated is often — but not always — considered the country of origin, since die fabrication is typically the most complex and value-adding step. Assembly and packaging in a different country does not automatically confer origin there. Importers with complex supply chains should seek a binding ruling.