Earlier this year, the Trump Administration issued a new export licensing review policy and tariffs respectively impacting exports and imports of certain advanced semiconductors and computing items, with particular impact on artificial intelligence.
On January 13, 2026, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") issued a final rule (the "BIS Rule") revising its export license review policy under the Export Administration Regulations ("EAR") with respect to exports to China of certain advanced-node integrated circuits and related computing items used in artificial intelligence ("AI") applications.
Specifically, BIS revised the license review policy from a presumption of denial to case-by-case consideration, provided that the exporter certifies that the items are commercially available in the United States, there is sufficient domestic supply of the items in the United States, and certain security requirements will be met.
As described below, the required certification is a high bar, and requires information known only to a limited segment of the industry.
The following day, President Trump signed Proclamation 11002 (hereinafter the "Proclamation"), imposing a 25 percent tariff on a "very narrow category" of advanced semiconductors and their derivative products used in artificial intelligence ("AI") applications — a significantly lower tariff than the 100 percent duty on all semiconductor imports originally mentioned by President Trump in August 2025.
Both effective January 15, 2026, the BIS Rule and the Proclamation establish a coordinated gating framework whereby foreign-produced advanced-node semiconductor items must be imported into the United States for security testing — and subject to a 25% tariff — before they can be exported to China under the more flexible BIS licensing policy.
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"Trade Rules: Trump Administration Revises Export Restrictions on Advanced Semiconductors While Levying Additional Tariffs," by Anthony Rapa and Rachel D. Evans was published in Reuters on March 13, 2026.