US tariffs in 2026: Section 232 chips, Section 122, then Section 301

US import tariffs changed legal basis three times in the past year, and each change touched electronics differently. On 14 January 2026 a Section 232 proclamation imposed a 25% tariff, effective 15 January, on a narrow category of advanced computing chips defined by processing-performance and DRAM-bandwidth thresholds, with exemptions for imports used in US data centres, research, start-ups and non-data-centre consumer and industrial applications, according to EY’s summary. Memory modules and SSDs were not the target; Commerce was asked to report on the data-centre chip market by 1 July before any broader action.

On 20 February the Supreme Court held 6 to 3 in Learning Resources v. Trump that IEEPA does not authorise the President to impose tariffs. Covington reports that the IEEPA tariffs were terminated for goods entered after 24 February and replaced by a 10% Section 122 tariff on products from all countries, limited by statute to 150 days, with certain electronics exempt under Annex II and Section 232 goods carved out. Refunds of IEEPA duties were left unresolved; importers were advised to confirm liquidation dates and protest deadlines, and early reports suggested CBP might require a court order before paying.

What replaced Section 122

The Section 122 surcharge expired on 24 July 2026 and was replaced the same day by Section 301 tariffs of 10% or 12.5% on imports from around 60 economies, tied to USTR findings on enforcement of forced-labour bans. BorderBuddy’s summary places Canada, Mexico, the EU, the UK, India and Taiwan in the 10% tier and China, Vietnam, Thailand, Japan and South Korea at 12.5%, with the figure for some trade-deal partners a combined ceiling that includes normal duty. Semiconductors and Section 232 goods are exempt; finished consumer electronics are treated more narrowly than under Section 122, so HTS classification must be confirmed item by item. Unlike Section 122, Section 301 has no expiry date, and the new duties stack on MFN rates, the 2018 China tariffs and any anti-dumping duties, so China-origin goods face the highest combined totals.

Z2Data’s advice to electronics buyers is to trace origin beyond final assembly to the sites where the semiconductors were made, to recalculate landed cost by region, and to track the Federal Circuit appeal and congressional proposals that could change the position again.

What it means for buyers

For buyers in the Gulf, Central Asia and Africa the US tariffs apply only to goods entering the United States, but they shape where vendors route stock and how they price by region. Memory and SSD pricing in 2026 is driven by the supply shortage rather than by tariffs; what tariffs change is the attractiveness of US-bound channel inventory, which can tighten or loosen what is offered in Dubai. Ask for the country of origin on quotations, keep purchase contracts on DAP or DDP Dubai terms so that duty changes elsewhere do not reopen pricing, and prefer stock already in region for urgent requirements. InTechnologies holds inventory in Dubai, which keeps the US tariff position out of the landed cost for its customers.