SMT Blog

Tariffs on Electronics: What's Exempt and What's Not

Written by Brian Lamers | April 21, 2025

 

As global supply chains continue to shift, US tariffs on electronics - particularly on components sourced from China - are becoming a critical cost driver for OEMs and electronics manufacturers.  With the recent implementation of a 125% reciprocal tariff, alongside longstanding Second 301 tariffs and IEEPA-related duties, importers are now facing increasingly complex sourcing decisions.

While some electronics categories are exempt, key segments like Printed Circuit Boards (PCBs) and Printed Circuit Board Assemblies (PCBAs) remain heavily taxed.  Here's a breakdown of what's currently exempt, what isn't, and how manufacturers can take advantage of CHIPS Act Incentives to stay competitive.

 

Understanding the US Tariff Stack on Electronics

As of April 2025, most China-origin electronics are subject to multiple layers of import duties:

  • 25% Section 301 Tariff
  • 20% IEEPA Emergency Tariff
  • 125% Reciprocal Tariff

For many electronics categories, these tariffs add up to a 170% cost increase - particularly for PCBs and PCBAs, which are seeing limited exemptions.

 

What's Exempt Under the New US Electronics Tariff Policy?

The IPC (Institute for Printed Circuits) recently published a list of HTS codes that are exempt from the new 125% reciprocal tariff.  These exemptions offer targeted relief to strategic areas of the electronics supply chain, such as:

  • Semiconductor devices (e.g., diodes, transistors, LEDs)
  • Solid-stage storage (SSDs, memory cards)
  • Data processing equipment (servers, CPUs, peripheral parts)
  • Telecommunication devices (routers, wireless modules)
  • Flat panel and display modules

These categories have been prioritized to support CHIPS Act goals and preserve domestic access to advanced computing and semiconductor components.

 

PCB Tariffs and Exemptions: What's Still Fully Taxed?

Despite advocacy from industry groups, relief for PCBs and PCBAs remains limited.  The following products are still subject to the full 170% tariff burden when imported from China:

  • 6+ layer rigid PCBs
  • All other bare PCB types
  • Fully assembled PCBAs

Even 2-4 layer rigid PCBs, which are temporarily exempt from Section 301, still face 145% total duties - a major challenge for cost-competitive, import-reliant designs.

 

Classification Matters: HTS Codes for PCBs and PCBAs

Proper HTS classification is essential to managing tariff exposure.  PCBs and PCBAs often fall under:

  • 8534 - Printed Circuits (bare boards)
  • 8537 - Control panels or assemblies
  • 8542 - Electronic integrated circuits
Beware of Dual Classification and Origin Pitfalls

Some assemblies may require dual classification, especially if they include control functionality or integrated circuits.  Precise datasheets and part-level documentation are critical to avoiding misclassification, delays, or penalties.

Also note: Country of origin matters.  A PCBA assembled in Vietnam using Chinese-origin PCBs may still trigger tariffs under US rules of origin.

 

Strategic Takeaways: How to Navigate Tariff Challenges

To reduce exposure and align with US policy incentives, manufacturers should consider these strategies:

  • Reevaluate sourcing by identifying alternate countries of origin
  • Consider domestic manufacturing to reduce tariff risk and boost CHIPS Act eligibility
  • Engage early with EMS providers like SMT to align design, procurement, and logistics
  • Monitor USTR and IPC updates for changes to duty rate and exemption lists

 

How SMT Supports Tariff-Smart Sourcing

At SMT, we understand that navigating tariffs isn't just about knowing the numbers - it's about having a proactive sourcing strategy.  If you're looking to reduce your tariff burden, we offer alternative sourcing options in Vietnam, Mexico, and the US to help shift away from China-origin components.  For companies exploring reshoring or domestic production, SMT can align your builds with CHIPS Act incentives to support both compliance and cost-efficiency.  From quick-turn prototypes to full-scale production, we provide flexible, transparent, end-to-end support throughout your product's lifecycle.

 

To learn more about SMT and how we support Tariff-Smart sourcing, click below.