SEMI has submitted comments to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) in response to its Section 232 National Security Investigation of Imports of Robotics and Industrial Machinery.
The submission highlights the vital role robotics and precision machinery play in semiconductor fabrication, packaging, and inspection and emphasizes the need for a balanced, risk-based approach to any future trade actions that strengthen U.S. national security while preserving access to robotics and industrial machinery essential to expanding the domestic semiconductor industry.
SEMI Recommendations
SEMI outlined five key recommendations to the Administration.
- Encourage Investment and Maintain Existing Competitiveness. SEMI recommends excluding essential robotics and industrial machinery where domestic sourcing is not yet viable. If trade actions are taken following the investigation, SEMI recommends providing tariff reductions or waivers for companies investing in U.S. manufacturing capacity. SEMI emphasized protecting small and medium suppliers that keep the ecosystem running.
- Avoid Stacking Tariffs. Coordinate Section 232 actions across potentially overlapping actions and ongoing investigations, such as on imports of steel and aluminum, semiconductors, critical minerals, and polysilicon. This will help prevent duplicative or compounding tariffs that could raise costs and slow U.S. capacity building.
- Implement Adjustment Periods and Sunset Provisions. SEMI recommends any trade actions should phase in gradually to allow for domestic adaptation and include regular review mechanisms to recalibrate as the market evolves.
- Pair Trade Actions With R&D, Workforce, and U.S.-Allied Collaboration. Strengthen domestic capacity through targeted federal research and development (R&D) programs, workforce training, and deeper partnerships with trusted U.S. allies to build resilient technology ecosystems.
- Develop a National Robotics Strategy. Given robotics’ foundational role across semiconductor and advanced manufacturing sectors, SEMI recommends that the Administration develop a National Robotics Strategy. The strategy should align federal programs including those at NIST, NSF, and Department of Energy to accelerate robotics innovation, update technical standards, and drive U.S. leadership in automation and manufacturing competitiveness.
The Global Context
Worldwide installations of industrial robots surpassed 540,000 units in 2023, with the market projected to exceed $73 billion in 2025.
Robotics and industrial machinery are integral to semiconductor production ensuring cleanroom integrity, precision, and throughput. Broad or overlapping tariffs could raise costs and undermine U.S. competitiveness at a time when historic investments in domestic semiconductor manufacturing are taking hold.
Next Steps
SEMI looks forward to working with the Department of Commerce and other federal partners to ensure that Section 232 policies enhance both U.S. national security and the industry’s global competitiveness.
Read SEMI’s full submission on Regulations.gov by searching Section 232 Investigation of Imports of Robotics and Industrial Machinery (XRIN 0694-XC138).
