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22 April 2025

Notice Of Request For Public Comments On Section 232 National Security Investigation Of Imports Of Semiconductors And Semiconductor Manufacturing Equipment

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In an era marked by global unrest, regulatory complexities, and a shifting market landscape, companies must remain diligent in their trade compliance procedures and stay apprised of changes in the law.
United States International Law

In an era marked by global unrest, regulatory complexities, and a shifting market landscape, companies must remain diligent in their trade compliance procedures and stay apprised of changes in the law.

TC Trade Alerts will serve as a central resource for identifying the policy changes, executive orders, and necessary information and context regarding government actions affecting international trade.

See below for more information on the last TC Trade Alerts. If you have any questions about how this affects your business, please don't hesitate to contact one of our attorneys.

Additional Resources

Trade Compliance Handbook | Checklists of Foreign Countries Subject to Sanctions | Our International Trade Practice

THOMPSON COBURN TRADE ALERT – IMPORTS
HEADLINE Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Semiconductors and Semiconductor Manufacturing Equipment
DATE April 16, 2025
AGENCY Department of Commerce; Trump Administration
EFFECTIVE DATES Deadline to Submit Comments in Docket No. 250414-0066 – May 7, 2025 (21 Days after Publication Date)
BACKGROUND On April 1, 2025, the Trump Administration directed the Secretary of Commerce to conduct a 232 investigation into semiconductors, semiconductor manufacturing equipment ("SME"), and their derivative products to determine whether such imports impair the national security of the United States.
DETAILS The Department of Commerce's Bureau of Industry and Security is seeking written comments, data, and information related to the national security impacts of semiconductors, SME, and their derivative products.

The Department is specifically interested in receiving comments and information regarding the following areas:

  • Current and future demand for semiconductors (including as embedded in downstream products) and SME differentiated by product type and node size
  • Ability of domestic production of semiconductors at each node size for each product type, and production of SME to meet demand
  • Role of foreign supply chains, particularly from major exporters, in meeting U.S. demands
  • Concentration of U.S. semiconductors imports (including as embedded in downstream products) and SME imports from a small number of suppliers and the associated risks
  • Impact of foreign government subsidies, overcapacity, and predatory trade practices on domestic industry competitiveness
  • Impact of low semiconductor and SME prices due to unfair trade practices and state-sponsored overproduction
  • Risks from potential export restrictions by foreign nations
  • Feasibility of expanding domestic semiconductor (in different product types and node sizes) and SME production to reduce dependence on imports
  • Impact of current trade policies on domestic semiconductor and SME production and whether additional measures, including tariffs or quotas, are necessary to protect national security
  • What product types and node sizes could be built only using SME from U.S. companies
  • What SME is manufactured abroad and faces limited competition from U.S.-made products
  • What SME parts or components are only available outside the United States
  • Where domestic workforce faces a talent gap in production of semiconductors, SME, or SME components

Please refer to the Notice linked below for filing instructions. Comments can be submitted electronically at www.regulations.gov, ID: BIS-2025-0021, and all comments should refer to XRIN 0694-XC121

BASIS Section 232 of the Trade Expansion Act of 1962; part 705 of the National Security Industrial Base Regulations (15 CFR parts 700 through 709)
CITE Federal Register: Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Semiconductors and Semiconductor Manufacturing Equipment

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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