The Software & Information Industry Association (SIIA) submitted comments to the U.S. Department of Commerce regarding the Section 232 investigation into the national security implications of importing semiconductors and semiconductor manufacturing equipment (SME). SIIA expressed concern that imposing tariffs would harm rather than enhance U.S. economic and national security.
Key points include:
- Lack of National Security Risk: SIIA argues that imported semiconductors do not pose clear national security threats. The U.S. leads in semiconductor design and R&D, maintains a trade surplus in several semiconductor sectors, and imports primarily from allied countries like Taiwan, Japan, and South Korea.
- Potential Harm of Tariffs: Tariffs could raise costs for U.S. companies in critical sectors such as artificial intelligence, impeding innovation and undermining national security capabilities that depend on advanced chips.
- Existing Onshoring Momentum: The U.S. has already made substantial progress in expanding domestic semiconductor manufacturing, driven by strong private investment and public incentives. More than $540 billion has been invested across 100+ projects in 28 states, with U.S. advanced chip production expected to grow significantly by 2032.
- Alternative Measures Preferred: SIIA recommends non-tariff strategies to strengthen supply chain resilience, similar to past Section 232 cases where tariffs were avoided in favor of increasing domestic production and deepening collaboration with allies.
SIIA concludes that tariffs are unnecessary and potentially counterproductive, given current U.S. leadership in the semiconductor sector and existing efforts to boost domestic capacity.
