The Computer & Communications Industry Association (CCIA) has submitted comments to the Department of Commerce regarding a Section 232 investigation into semiconductor imports. The focus of the investigation includes semiconductors, semiconductor manufacturing equipment, and derivative products.
In its submission, CCIA provided recommendations on how the U.S. government could address national security concerns related to advanced technologies while considering the global nature of semiconductor supply chains. The association emphasized the United States' leadership in advanced design and its increasing capacity in advanced manufacturing. It suggested that the government should narrow the scope of its investigation and utilize existing mechanisms to strengthen secure supply chains. This could be achieved through domestic incentives for reshoring and collaboration with key international partners.
Jonathan McHale, Vice President of Digital Trade at CCIA, commented on the matter: “Dependencies on China for critical portions of the global semiconductor supply chain are a valid concern, but with significant sourcing coming from trusted partners, global tariffs and similar remedies could inflict a net harm: simply raising costs for U.S. users without a credible path towards sustainable reshoring makes little sense." He further advised that "policy interventions to alter this highly-complex supply chain should not be rushed" and recommended relying on proven approaches such as incentives for domestic manufacturers and close coordination with Taiwan, Japan, the Netherlands, South Korea, and the EU.