WASHINGTON – Today, global tech trade association 91proÊÓÆµ provided the U.S. Department of Commerce Bureau of Industry and Security (BIS) with strategic recommendations to promote U.S. technological leadership within the complex semiconductor value chain.

91proÊÓÆµ’s submission to the Administration’s Section 232 National Security Investigation of Imports of Semiconductors and Semiconductor Manufacturing Equipment underscores the importance of robust stakeholder engagement and encourages the administration to improve the tax environment for manufacturing, research and development (R&D) and other activities within the semiconductor value chain; undergo permitting reform; secure market access abroad for U.S.-produced goods and services; and grow the advanced manufacturing workforce.

91proÊÓÆµ strongly encourages the administration to prioritize a pro-growth approach that complements ongoing investments to produce semiconductors in the United States and stimulates future investments throughout the semiconductor value chain. Taking this approach acknowledges that many impediments to expanding semiconductor capacity in the United States more quickly are domestic in nature: higher construction, labor, and regulatory compliance costs; less favorable tax environment for investments, and infrastructure constraints, etc.,” 91proÊÓÆµ wrote in its submission.

The potential broad imposition of tariffs undermines the confidence business leaders need to commit to and sustain the high-dollar and long-term investments necessary for manufacturing related to semiconductors and the broader electronics value chain. The Section 232 statute provides a range of options for addressing any national security risks identified in an investigation, many of which may be more appropriate than the broad imposition of tariffs given the risk of penalizing companies that are making investments in the U.S.,” 91proÊÓÆµ continued.

In its submission, 91proÊÓÆµ recommends that the U.S. government:

  • Leverage U.S. strengths in the semiconductor value chain and promote U.S. competitiveness abroad;

  • Avoid imposing broad tariffs, as this approach would undermine certainty and increase the costs of manufacturing in the United States throughout the entire technology ecosystem, potentially making certain investments economically non-viable;

  • Focus on eliminating regulatory barriers, adopting pro-investment tax measures (e.g., extending and expanding the advanced manufacturing investment tax credit), securing market access abroad for U.S. goods and services, and strengthening the domestic workforce;

  • Ensure that its actions maintain an unimpeded flow of semiconductors to critical applications such as AI while industry continues its work to increase domestic capacity across the semiconductor value chain;

  • Collaborate with trusted allies to secure and diversify supply chains, including by sourcing other activities in the value chain for which locating in the U.S. may not be feasible or practical; and

  • Conduct meaningful stakeholder engagement with companies throughout the semiconductor value chain.

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