Electronics & Semiconductors Electronics trade compliance
Prove origin before the module ships.
A Taiwan design, a China board and a Mexico line can give one module three answers. GingerOS keeps the code, the origin reasoning and every Chapter 99 line on each part, for every entity.
GingerOS- HTS
8504.40.95- Origin
- China
- Imported by
- Monterrey plant, MX
- Entry
- 10/06/2026
Duty stackTotal duty37.5%
- Base duty (MFN)
Free - Section 301, List 3
9903.88.0325% - Section 301, forced labor
9903.05.3112.5% - USMCA, MexicoSimple assembly in Mexico does not make it Mexican
9903.05.94Not applied
Plus MPF 0.3464%, and HMF 0.125% by ocean
Why The Monterrey line only bolts the Chinese board into a case, so the module stays Chinese: List 3 plus the 12.5% forced-labor line. If the Mexico work changes it into a new article and it meets the USMCA rule, both lines drop away.
A GingerOS part record with demo data for electronics & semiconductors: AC-DC power supply module, HTS 8504.40.95, from China. Each duty layer is listed with its rate or exemption, for a total duty of 37.5%.
What tariffs hit imported electronics now?
Origin and the line decide it: China adds List 3 and 12.5%, Taiwan tops up to 10%, the exempt list pays none of it.
Most electronics enter at a free base rate, so origin and the exact line decide the duty. Since July 24, 2026 a Section 301 forced-labor duty adds 12.5% to Chinese goods on top of their China-list rate and tops Taiwan goods up to a combined 10%. Lines on its exempt list, including 8471 computers, 8473.30 computer parts, 8517.62 network gear and most chips, pay none of it. Mexican goods escape only when entered free under USMCA. The Section 232 chip tariff covers only advanced AI chips.
Recent Policy UpdatesNotices that touch electronics
- Federal Register Notice91 FR 47318Forced-labor Section 301: Taiwan goods topped to 10%, China plus 12.5%, USMCA exempt
A free-rated module from Taiwan now pays 10%; lines on the note 52(b) list, such as 8471, 8473.30 and most chips, are exempt from every origin.
9903.05.31, .55, .76; exemptions 9903.05.86, .94Read the explainer - Presidential ProclamationProclamation 11002Section 232 chip tariff: 25% only on advanced AI chips in 8471.50, 8471.80, 8473.30
Only logic chips above the performance thresholds pay 25%; end-use exemptions apply, and no drawback is available on this duty.
9903.79.01 to 9903.79.09Read the explainer - Federal Register Notice90 FR 60848China legacy-chip Section 301 at 0% for now, rising June 23, 2027 on top of 50%
Chinese chips, wafers and polysilicon keep the 50% list rate; the extra rate is announced at least 30 days before. Downstream products are not on the list.
2804.61, 3818, 8541, 8542 - Federal Register Notice90 FR 50857BIS 50% affiliates rule paused until November 9, 2026
From November 10, unless extended, a customer 50% or more owned by Entity List parties is treated as listed. Check owners before shipping.
EAR, any ECCN or EAR99
A Compliance Radar feed of 4 recent policy updates that touch electronics & semiconductors, each with its source, reference and effective date.
Is this power board a converter or a computer part?
A complete power supply stays in 8504.40 and pays the forced-labor 301; a computer part in 8473.30 is exempt.
Open-frame AC-DC power supply board, built for one server model. Made in Taiwan.
Ginger asksDoes the board convert AC to regulated DC on its own, or can it only work through the server's own board?
It converts on its own: AC in, 12 V DC out.
8504.40.6018HTS rate Free
Static converters for incorporation into machines of heading 8471: other
Forced-labor 301 applies: Taiwan tops up to 10%; China List 3 25% plus 12.5%
8473.30.1180HTS rate Free
Parts of machines of heading 8471: printed circuit assemblies, other
On the note 52(b) exempt list: no forced-labor 301; China List 3 25%
Deciding rule Section XVI Note 2(a): parts that are goods of their own heading in Chapter 84 or 85 go to that heading, not to 8473; CBP HQ 967514 (2005) classified a power supply in 8504.40.
A Classification Researcher conversation with demo data. Ginger asks: Does the board convert AC to regulated DC on its own, or can it only work through the server's own board? From the answer it picks HTS 8504.40.6018 over 8473.30.1180.
What does this mean when no one owns compliance?
Every plant move, board change or China order opens one recheck: the code, the origin, or the export classification.
GingerOSDoes what the Mexico plant makes count as Mexican origin, and can this module ship to Kunshan?
Open rechecks3
8504.40.95Monterrey plant, MXBoard assembly moved from China to MexicoCompare China and Mexico origin landed costRuns in Parts LibraryNeeds answer8504.40.95Hsinchu HQ, TWOrder from a customer in KunshanClassify the ECCN before it shipsRuns in Export Control ClassifierReview8473.30.1180Hsinchu HQ, TWForced-labor 301 exempt list (note 52(b))Confirm 8473.30, not 8504.40, for the exemptionRuns in Classification ResearcherNeeds answerA GingerOS window with demo data. Someone asks: "Does what the Mexico plant makes count as Mexican origin, and can this module ship to Kunshan?" It lists 3 open rechecks, each with the part, HTS code, trigger, tool and status.
Questions about electronics compliance
Does a module built in our Mexico plant count as Mexican origin?
Only if the Mexico work changes what the parts are. For Section 301 and the forced-labor duty, CBP applies the substantial transformation test; for the USMCA claim, the module must meet its product-specific rule of origin. In NY N325943 (2022), Chinese power supplies bolted into cabinets in Canada stayed Chinese for marking and Section 301, so simple assembly in Mexico can leave a module Chinese.
What duty does a Taiwan-made electronic module pay in October 2026?
Most Taiwan modules with a free base rate pay 10%. Since July 24, 2026, heading 9903.05.76 tops Taiwan goods up to a combined 10% (91 FR 47318). Lines listed in U.S. note 52(b), including 8471 computers, 8473.30 computer parts, 8517.62 network equipment and most 8541 and 8542 semiconductors, are exempt. MPF of 0.3464% applies, plus HMF of 0.125% on ocean shipments.
Do USMCA goods from Mexico avoid the Section 301 forced-labor duty?
Yes, but only when they are entered free of duty under USMCA. Heading 9903.05.94 exempts products of Mexico entered under the agreement, so a qualifying module entered without the USMCA claim still pays 10% under heading 9903.05.55 (91 FR 47318). The claim has to rest on the module's rule of origin, so keep the analysis for each part.
Is a server power supply classified as a computer part under 8473.30?
Usually not. Section XVI Note 2(a) sends parts that are themselves goods of a Chapter 84 or 85 heading to their own heading, so a complete AC to DC power supply belongs in 8504.40 even when built for one machine, as CBP reasoned in HQ 967514 (2005). The choice now matters: 8473.30 parts are exempt from the forced-labor duty, 8504.40 power supplies are not.
Are Chinese semiconductors facing new tariffs in 2026?
Chinese chips keep the 50% Section 301 rate under heading 9903.91.05, and USTR's December 2025 action adds a further increase on June 23, 2027, at a rate to be announced at least 30 days earlier (90 FR 60848). The separate 25% Section 232 chip tariff covers only advanced logic chips in 8471.50, 8471.80 and 8473.30 that meet set performance thresholds (Proclamation 11002).
Can we ship this module to a customer in Kunshan without an export license?
It depends on the module's export classification, the customer and the end use, not on the city. Items subject to the EAR but not on the Commerce Control List are EAR99, yet Entity List parties and military end uses can still require a license. BIS suspended its rule treating 50% owned affiliates as listed only until November 9, 2026 (90 FR 50857).
Does the Section 232 chip tariff stack with the forced-labor Section 301 duty?
No. U.S. note 52(f)(7) excludes semiconductor articles under heading 9903.79.01 from the forced-labor duty, so a covered advanced chip pays the 25% Section 232 rate instead (91 FR 47318; Proclamation 11002). Most other 8541 and 8542 lines are exempt under note 52(b), though solar cells in 8541.42 and 8541.43 are not listed. No drawback is available on the semiconductor Section 232 duty.
What changes on December 4, 2026 for wafer and solar cell imports?
Proclamation 11052 starts a minimum import price program and a 15% Section 232 duty on the polysilicon ingots, wafers, solar cells and modules listed in its annexes, for entries from December 4, 2026. For products of Taiwan, Japan, Korea, Switzerland, Liechtenstein and EU members, the Section 232 duty plus the Column 1 rate equals 15%.
