Comprehensive guide to US import tariffs on China-made electronics: Section 301 (50% on semiconductors), Section 122 global surcharge (10%), and HTS codes.
Electronics manufactured in China face three overlapping tariff layers in 2026: the MFN base rate (0–3.9%), the Section 122 global surcharge (10%), and — for semiconductors and many electronic components — the Section 301 List 3/4A surcharge (25–50%). Combined, China-origin integrated circuits now carry a 60–64% effective duty rate. This guide explains each layer, which HTS codes are affected, and how to calculate landed cost.
Section 301 tariffs under the Trade Act of 1974 were first applied to China in September 2018 (List 3, 25%) and expanded in September 2019 (List 4A, 7.5%, later raised). In 2025, the Biden administration raised List 3/4A semiconductor rates to 50% effective January 1, 2025 — meaning ICs under HTS 8541/8542 from China now carry a 50% Section 301 surcharge alone. Other electronic components (PCBs, connectors, power supplies) remain at 25%. Consumer electronics like phones and laptops were excluded from List 4A when Section 301 was first applied but now face the 10% Section 122 surcharge.
Executive Order 14228 imposed a 10% global tariff on all imports under 19 U.S.C. § 2132, effective February 24, 2026. This applies to all countries including China, stacking on top of existing Section 301 rates. For China-origin semiconductors: 50% (Section 301) + 10% (Section 122) = 60% additional duty. For Chinese-made passives, connectors, and PCBs: 25% (Section 301) + 10% (Section 122) = 35% additional. USMCA goods (Mexico/Canada) are exempt from Section 122.
Beyond tariffs, the BIS Entity List restricts exports to and imports from certain Chinese semiconductor makers. YMTC (Yangtze Memory Technologies Co.) was added to the Entity List in December 2022, restricting US companies from selling to YMTC and creating compliance risk for YMTC-branded NAND. While tariffs are applied at CBP, Entity List compliance is enforced by BIS — separate processes requiring separate diligence.
Key HTS codes: 8542.31 (processors/controllers, 0% MFN + 60% additional = 60% total from China), 8542.32 (memory ICs, same), 8541.10 (diodes, 0% MFN + 60% = 60%), 8536.90 (connectors, 0% MFN + 35% = 35%), 8534.00 (PCBs, 0% MFN + 35% = 35%), 8473.30 (laptop/PC parts, 0% MFN + 10% = 10% — Section 301 exempted), 8471.30 (laptops, 0% MFN + 10% = 10%).
Companies reducing China tariff exposure in 2026 use several approaches: (1) China+1 manufacturing — shifting assembly to Vietnam, India, or Mexico while retaining China for some components; (2) First Sale valuation — using the factory price rather than middleman price for customs value; (3) De minimis optimization — splitting small orders under $800 threshold where applicable; (4) Tariff engineering — modifying products to qualify for lower-duty HTS codes; (5) Foreign Trade Zones — deferring or reducing duty on goods destined for re-export.
| HTS Code | Description | MFN Rate | Examples |
|---|---|---|---|
| 8542.31 | Processors / microcontrollers | Free | 60% total (301 50% + 122 10%) |
| 8542.32 | Memory ICs | Free | 60% total (301 50% + 122 10%) |
| 8541.10 | Diodes & rectifiers | Free | 60% total (301 50% + 122 10%) |
| 8536.90 | Connectors & switches | Free | 35% total (301 25% + 122 10%) |
| 8534.00 | Printed circuit boards | Free | 35% total (301 25% + 122 10%) |
| 8471.30 | Laptops / notebooks | Free | 10% total (Section 122 only) |
| 8517.13 | Smartphones | Free | 10% total (Section 122 only) |
Smartphones under HTS 8517.13 were excluded from Section 301 List 4A. However, they are subject to the 10% Section 122 global surcharge effective February 2026. Apple has been accelerating India assembly partly to mitigate this exposure.
The Biden administration announced increases in May 2024, effective January 1, 2025. Semiconductors under HTS 8541 and 8542 from China increased from 25% to 50% Section 301 rate.
Section 122 is a global surcharge — it applies to all countries except those with qualifying trade agreements. USMCA partners (Mexico and Canada) are exempt. All other countries including China, Taiwan, Vietnam, India, and EU nations pay the 10% surcharge.
Total duty = MFN rate + Section 301 rate + Section 122 rate. For most semiconductors: 0% + 50% + 10% = 60%. Multiply the customs value (typically FOB price) by 60% to get the duty amount. Add freight, insurance, and CBP processing fees for total landed cost.
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