The US 2025 tariff exemption list landed, and the chip industry ushered in a key turnaround
-- Semiconductor materials, equipment and optical modules become the focus, localization requires or reshapes the supply chain
Introduction
The list of tariff exemptions officially released by the U.S. Department of Commerce in April 2025 lists the semiconductor industry as a priority exemption area. The new policy aims to ease pressure on the US chip supply chain, while strengthening control over key technologies through "localization" provisions. This adjustment may open a new window for global semiconductor companies, but it also hides games and challenges.
A,policy core: chip supply chain "precise loosening"
According to the details released by the White House, the chip industry exemptions are mainly focused on the following areas:
1, semiconductor materials and equipment : silicon wafers, photoresist, high-purity chemical gases and other key raw materials are exempt from customs duties (under the tax code 9903.01.32) ;
2, the tariff on wafer manufacturing equipment (such as etching machines and deposition equipment) is reduced from 25% to 5%, provided that the proportion of U.S. technology is ≥20%.
3, optical module products :
High-end optical modules using US enterprise chips (such as Broadcom and Nvidia DSP chips) can apply for 0% tariff, provided that the "US content" (including technology authorization) of the product is not less than 20%; Products related to sanctioned companies such as Huawei and SMIC are still excluded from the exemption.
4, chip tariff retroactive refund : for finished semiconductor products imported after April 9, 2024, if they meet the exemption conditions, enterprises may apply for a refund of the tariff paid .
B, industry impact: the supply chain accelerated "East-west separation"
1, American companies benefit :
Intel, Micron and other companies can import high-end raw materials from Japan and South Korea at low prices to reduce the production cost of advanced process chips; Chip design companies such as Broadcom and Marvell expanded their share in the optical module market through technology licensing.
2, Asian supply chain adjustment : after TSMC and Samsung put their factories into operation in the United States, the cost of imported equipment will drop, but the source of technology must meet the requirements of the United States; Wafer products from mainland Chinese companies such as SMIC and Shanghai Silicon industry may enter the exempt channel if they are exported to the United States through "unaffiliated third parties".
3, Opportunities and limitations for Chinese enterprises :
1) opportunities : rare earth materials (such as gallium, germanium), high-end ceramic substrates for chip packaging and other advantages of China that have not been clearly restricted, can take this opportunity to expand exports;
2) risk : Huawei hisilicon, Changjiang Storage and other enterprises included in the entity list, their supply chains are still facing "long-arm jurisdiction" blockade.
C,The focus of dispute: Two sides of the exemption policy
1, "technology bundle" clause has been challenged :
The US requirement for companies to use local technology or licensing in exchange for tariff relief has been criticised by the EU and South Korea as "disguised technology protectionism". For example, if TSMC wants to be exempt from the photoresist duty, it needs to purchase equipment from Applied Materials (AMAT) or Lam Research ().
2, high value-added chips are still limited :
High-end products such as logic chips below 14 nm and HBM memory chips are not included in the exemption list, which the US Department of Commerce said "needs to protect the leading position of local technology" .
3, Chinese enterprises "detour" possibility :
Some Chinese enterprises plan to assemble optical modules through joint venture factories in Mexico and Vietnam, and use the 0% tariff channel of the United States-Mexico-Canada Agreement (USMCA) to export to the United States, but need to avoid the "entity list" associated review .
D,Future outlook: The game is far from over
1, short-term benefits and long-term risks :
The exemption policy will reduce the cost of chip manufacturing in the United States in the short term, but localization requirements may push up the cost of global industrial chain division of labor; If Chinese enterprises can not break through the technical restrictions, the gap with the United States in the field of photoresist, EDA tools or further expand.
2, global enterprise accelerated layout :
TSMC announced that the Arizona plant will prioritize the purchase of American equipment;
South Korea's SK Hynix plans to build a semiconductor material storage center in the United States to quickly respond to the exemption list demand.
