The Software & Information Industry Association (SIIA), along with a coalition of leading industry associations, submitted comments to the U.S. Department of Commerce in response to the ongoing Section 232 investigation into the national security implications of semiconductor and semiconductor manufacturing equipment (SME) imports.

While SIIA strongly supports the goal of increasing domestic semiconductor manufacturing to enhance U.S. innovation and security, we joined fellow associations in expressing serious concerns about the potential imposition of tariffs on semiconductor imports and downstream electronics products.

The letter emphasizes that:

• • U.S. currently lacks sufficient capacity to meet semiconductor demand, and broad tariffs would raise costs and reduce availability across the economy.

  • Targeting derivative products risks sweeping in a vast array of electronics unrelated to national security, potentially affecting over $1 trillion in imports.

  • Tariffs could increase administrative burdens for manufacturers, particularly small businesses and startups, and disrupt critical supply chains.

  • Dual supply chains required to manage tariff regimes could reduce investments in R&D and hinder U.S. competitiveness.

  • U.S. Customs and Border Protection is already strained by existing trade measures, and additional complex tariffs would add further challenges.

SIIA urges the Department of Commerce to avoid sweeping trade restrictions that could inadvertently stifle innovation, burden U.S. businesses, and disrupt global competitiveness. We remain committed to working with policymakers to ensure a resilient and forward-looking semiconductor ecosystem in the United States.