Section 232 Actions on Semiconductors and Critical Minerals

Summary

The President has issued two proclamations under Section 232 of the Trade Expansion Act addressing national security risks tied to U.S. dependence on foreign supply chains for (1) certain semiconductors and (2) processed critical minerals. One action imposes immediate tariffs; the other initiates negotiations with the possibility of future trade measures.

Semiconductors and Semiconductor Manufacturing Equipment

Immediate Tariffs Effective January 15, 2026

Following an investigation by the U.S. Department of Commerce, the Administration concluded that reliance on foreign semiconductor supply chains poses a national security risk. U.S. production currently meets only a small share of domestic demand.

Key Measures

Importer Impact

Source: ADJUSTING IMPORTS OF SEMICONDUCTORS, SEMICONDUCTOR MANUFACTURING EQUIPMENT, AND THEIR DERIVATIVE PRODUCTS INTO THE UNITED STATES

Processed Critical Minerals and Derivative Products

No Immediate Tariffs; Heightened Monitoring

A separate Section 232 investigation found that U.S. dependence on foreign processing of critical minerals presents a national security risk. The U.S. is fully import-reliant for several critical minerals and lacks sufficient domestic processing capacity.

Key Measures

Importer Impact

Action Items for Importers

Source: ADJUSTING IMPORTS OF PROCESSED CRITICAL MINERALS AND THEIR DERIVATIVE PRODUCTS INTO THE UNITED STATES

Please reach out to your Buckland representative if you would like a product-specific impact review or assistance assessing exemption eligibility.