🧠 Food for thought

Implications, context, and why it matters.

Scope hinges on HTS codes, exemptions, and a July review

• Confirm coverage for HTSUS 8471.50, 8471.80, and 8473.30 (U.S. tariff classifications for computing units and parts). Items that meet the technical parameters face a 25% duty 1.
• Verify the initial focus on AI accelerators like Nvidia’s H200 and AMD’s MI325X 2. Exemptions use end‑use tests (how a chip will be used). Product‑type carveouts do not apply 2.
• Track how U.S. Customs and Border Protection (CBP) applies end‑use exemptions 1. Covered uses include data centers and research and development 1. Startups qualify, along with non‑data‑center consumer uses, civil industrial uses, and public‑sector applications 1. CBP will rely on importer certifications, which will decide who pays 1.
• Follow the July 1, 2026 status update that could change the tariff 2. Semiconductors used in U.S. data centers sit at the center of that review 2.
• Model landed costs with the no‑drawback rule and Foreign‑Trade Zone (FTZ) privileged foreign status 1. No‑drawback blocks duty refunds on re‑exports, and privileged status locks the duty rate when goods enter the FTZ 1.
• Quantify South Korean exposure by mapping shipments that meet the proclamation’s performance thresholds. Do not assume limited impact from the current memory exclusion cited by Seoul.

Two near‑term plays for on‑shore Outsourced Semiconductor Assembly and Test (OSAT) capacity and tariff navigation services

• OSAT operators and private equity (PE) investors should evaluate U.S. packaging and test builds that qualify as contributing to the U.S. technology supply chain 1. Amkor Technology has a $7B Arizona campus with production planned for early 2028, which shows demand and the long timeline to add capacity 3.
• Fabless startups and second‑tier accelerator vendors can pilot U.S. final assembly and packaging to align with supply‑chain contribution tests 1. Pair that move with end‑use exemptions for U.S. data centers and research and development to keep market access 1.
• Customs and trade‑law firms can build services around HTSUS 8471.50, 8471.80, and 8473.30 classifications 1. Add end‑use certifications, FTZ privileged‑status planning, and no‑drawback cash‑flow modeling that CBP will require via Federal Register (the government’s official rulemaking journal) changes 1.
• Equipment makers and workforce developers should time investments to the U.S. capacity wave 4. TSMC’s multi‑fab and advanced‑packaging build‑out will expand local downstream demand 4. Samsung’s Texas fab targeting 2026 operations will add to that demand 4. Support growth with advanced‑packaging projections of about $79B by 2030, plus U.S. funding earmarked for packaging 5.