On April 11, 2025, the China Semiconductor Industry Association (CSIA) issued an official notice clarifying the country-of-origin rule for integrated circuits (ICs). In accordance with the General Administration of Customs regulations, the origin of ICs is to be determined based on the wafer fabrication location, also known as the tape-out site.

This policy applies to both packaged and unpackaged chips. Importers must declare the wafer fab location as the country of origin during customs declaration, and be prepared to provide supporting documents such as purchase orders (POs) for verification purposes.

Strategic Background

This announcement comes amid China's response to the United States' implementation of "reciprocal tariffs." As part of countermeasures, China’s Tariff Commission has raised tariffs on U.S.-origin products from 84% to 125%.

The clarification on IC origin helps distinguish between chips that are only designed in the U.S. and those that are actually manufactured there. Since most U.S. fabless and IDM companies rely on overseas foundries, ICs fabricated outside the U.S. may be exempt from the increased tariffs. In contrast, U.S. semiconductor equipment—most of which is exported directly from the U.S.—may face heavier trade impacts.

Industry Implications

The IC industry has long debated the criteria for determining product origin, with some parties favoring the wafer fab location and others pointing to the final packaging site. The CSIA’s statement reinforces the wafer-level origin rule, in line with long-standing customs practices.

This move not only reflects China’s pragmatic approach to global trade but also provides clarity and consistency for enterprises involved in IC importation. It may further encourage global diversification in semiconductor manufacturing, supporting the resilience of the supply chain.

As a participant in the semiconductor ecosystem, AXTEK will continue to closely monitor policy developments and support customers in navigating import/export compliance efficiently.
In addition, with our warehouse located in Hong Kong, we are able to bypass tariff impacts by shipping directly from Hong Kong to global customers, ensuring stable and flexible supply.