The U.S. Department of Commerce has officially launched a national security investigation into the import of semiconductors and semiconductor manufacturing equipment (SME), inviting public comments to inform its review. This inquiry is being conducted under Section 232 of the Trade Expansion Act of 1962, a legal framework that allows the federal government to examine whether certain imports pose a threat to national security.
The Bureau of Industry and Security (BIS), part of the Commerce Department’s Office of Strategic Industries and Economic Security, is leading the investigation. The review covers a wide range of technologies including legacy and leading-edge semiconductor chips, substrates, wafers, microelectronics and manufacturing equipment, as well as downstream products containing these technologies.
Stakeholders—such as industry representatives, researchers, manufacturers and members of the public—are encouraged to submit relevant data, insights or analyses. The department is especially interested in how current import patterns, global supply chain dependencies, foreign subsidies and production capacities affect U.S. national security and economic resilience.
“The Commerce Department has initiated a Section 232 investigation on imports of semiconductors, semiconductor manufacturing equipment and their derivative products,” said Jonathan M. Zielinski, partner at Cassidy Levy Kent (USA) LLP. “The result could be additional tariffs on these imports from any country. The first step is for the public to submit comments about what products are and are not national security threats.”
Public comments must be submitted by May 7 through the federal portal at www.regulations.gov, referencing docket ID BIS-2025-0021 and XRIN 0694-XC121. Submissions that contain business confidential information must be appropriately labeled and accompanied by a non-confidential version.
Among the specific areas of interest to the Commerce Department are:
- U.S. demand and production capacity for semiconductors and SME by product type and node size;
- Dependence on foreign fabrication and assembly services;
- Risks from import concentration or reliance on limited overseas suppliers;
- Effects of foreign government subsidies and unfair trade practices;
- Vulnerabilities to export restrictions or supply chain weaponization;
- Domestic talent gaps in semiconductor and SME production;
- Feasibility of increasing domestic manufacturing to reduce reliance on imports.
“To the extent any International Card Manufacturers Association (ICMA) member wants to comment on whether smartcard chips should or should not be included, I’m happy to discuss the process individually or as a group” Zielinski said.
The investigation also seeks public views on whether policy changes—such as tariffs or quotas—may be needed to protect critical U.S. industries and supply chains.
For additional information, interested parties can contact Stephen Astle, director of the Defense Industrial Base Division. Background on previous Section 232 investigations and related regulations can be found at bis.doc.gov/232.
To learn more, attend Zielinski’s presentation, “Tapping into Trade – Navigating Recent Actions in the International Trade of Smart Cards,” at 9:30 a.m. on Thursday, May 15 during ICMA’s Card Manufacturing & Personalization EXPO. For more immediate questions about the Section 232 process and the May 7 comment deadline, please contact him directly at jzielinski@cassidylevy.com.
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