Corporations from major semiconductor-producing countries such as South Korea, Japan, and Taiwan have expressed concerns and requested restraint regarding the U.S. government's push for semiconductor tariffs. They warned that the imposition of tariffs could lead to supply chain instability and increased expenses, ultimately having a negative impact on the U.S. industry.
According to the U.S. Federal Register, published on the 21st (local time), the U.S. Department of Commerce received a total of 206 comments related to the ‘Trade Expansion Act Section 232’ investigation concerning imported semiconductors, manufacturing equipment, and derivative products. The investigation serves as a basis for imposing tariffs on specific imports under the pretext of national security and aims to protect the semiconductor industry within the United States.
The South Korean government emphasized in its submitted comments that the U.S. and South Korea maintain a complementary relationship in memory semiconductor and logic chip manufacturing equipment. It pointed out that tariffs could undermine this supply chain structure, particularly as high bandwidth memory (HBM) and advanced dynamic random-access memory (DRAM) are essential components for the U.S. artificial intelligence (AI) infrastructure. Therefore, a strategic and cautious approach is requested.
Additionally, given that South Korean corporations are constructing semiconductor plants in the U.S., they noted that the import of equipment and materials is inevitable and requested 'special consideration,' citing that tariffs could negatively affect investment in the U.S. The Korea Semiconductor Industry Association also submitted a separate letter with similar content to the government.
The Japanese government emphasized that no single country can independently internalize the semiconductor value chain, pointing out that tariffs could burden U.S. semiconductor demand corporations and designers. They also conveyed a position to continue supply chain cooperation while requesting a review of tariffs on manufacturing equipment, materials, and derivative products.
The Taiwanese government requested an exemption from tariffs on Taiwanese semiconductors, using the phrase 'essential partner in making America great again.' Taiwan Semiconductor Manufacturing Company (TSMC) argued that companies that have promised investments in the U.S. should be treated as exceptions from tariffs and import restrictions.
The Chinese government criticized the U.S. for arbitrarily expanding the concept of 'national security' to apply protectionist measures on semiconductors, following actions related to steel, aluminum, and automobiles. It claimed that the current investigation violates World Trade Organization (WTO) regulations and that large-scale subsidy policies have led to an unfair competitive advantage.
The European Union (EU) also expressed concerns, stating that attempting to protect industries under the pretext of national security is worrying. The EU warned that measures destabilizing the semiconductor supply chain and undermining trade trust could damage the collaborative relationship between South Korea and the U.S.
U.S. corporations also voiced negative positions. The Semiconductor Industry Association (SIA) noted that tariffs could increase domestic semiconductor production and technology development expenses, stating that even in unavoidable circumstances, mitigation measures such as introducing a tariff-rate quota (TRQ) are necessary. Intel argued that equipment and materials for which there are no alternatives in the U.S. and wafers produced based on U.S. intellectual property should be recognized as exceptions.
The Automotive Innovation Alliance (AAI), representing automobile manufacturers, warned that if the production expenses increase due to a large volume of semiconductors installed in vehicles, the competitiveness of finished vehicles in the U.S. could weaken.
Industries that do not directly produce semiconductors are also paying attention to the impact of this expanded investigation. The Korea Display Industry Association requested that semiconductors within display modules, being a general-purpose technology with a small proportion, should be excluded from the classification of derivative products. Hanwha Qcells requested that solar wafers, being different from semiconductor wafers, should also be excluded from the investigation.