On the evening of April 11th local time, the US Customs and Border Protection (CBP) issued an updated tariff guideline, exempting 20 product categories listed in the Harmonized Tariff Schedule of the United States (HTSUS) from the “reciprocal tariffs” under Executive Order 14257. This exemption covers semiconductor-related products such as chips, laptops, smartphones, and flash drives. The exemption applies to goods entering the country after April 5th, and taxes already paid may be eligible for refunds.
Verification of media reports suggesting that “solar cells are included in the exemption list” indicates that the exemption list does not explicitly mention solar cells. The current tariff codes for mainstream crystalline silicon solar cells—8541.42.0010 (unassembled cells) and 8541.43.0010 (module cells)—are not included in the exemption. Tariff code 8541.51.00 corresponds to light-emitting diodes (LEDs) and other semiconductor transducers, while 8541.59.00 refers to non-LED semiconductor products, neither of which are related to photovoltaic devices.
Documents from the US International Trade Commission’s 2024 anti-dumping and countervailing duty investigations into crystalline silicon photovoltaic cells from Cambodia, Malaysia, Thailand, and Vietnam show that these tariff-coded products are listed as targets for “anti-dumping and countervailing duties,” further confirming that they are not included in the exemption. Additionally, the final ruling from the 2024 second sunset review of anti-dumping and countervailing duties on Chinese crystalline silicon photovoltaic cells indicates that these products still face high tariffs.
Notably, the exemption has been explained by White House officials as “buying time for tech companies to relocate production lines.” However, Commerce Secretary Howard Lutnick clarified on April 14th that the exemption is a temporary measure and that relevant products may be included in upcoming semiconductor industry tariffs. President Trump emphasized the same day on social media that the exemption does not signify that China is “off the hook,” and that the US will initiate a national security tariff investigation into the semiconductor and electronics supply chain, with details to be announced on Monday, April 14th.
Analysts point out that while some products in the semiconductor sector have received tariff reductions, photovoltaic products such as solar cells remain subject to trade barriers. The Chinese Ministry of Commerce responded on the 13th by stating that it is assessing the impact and urging the US to completely eliminate the erroneous practice of “reciprocal tariffs.” Currently, 73% of US smartphones and 78% of laptops rely on the Chinese supply chain. The exemption measures may temporarily alleviate consumer price pressures, but long-term policy directions remain uncertain.
