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52 SMT007 MAGAZINE I NOVEMBER 2026 ceiling for Japan, Korea, and Switzerland is 12.5%. The action arrived as the administration attempted to rebuild its tariff architecture after the Supreme Court struck down its previous tariffs issued under the International Emergency Economic Powers Act (IEEPA). Section 301 now functionally recreates part of the broad country-based framework, alongside Section 232 and other authorities. One distinction to note: These duties respond to economy-wide policies and enforcement. They are not findings that every covered shipment or product was made with forced labor. Section 301 can reach goods unrelated to the investigated practice. The Scope and Limits to the Electronics Carve Outs Universal exclusions broadly cover high-purity silicon and silicon carbide; doped semiconductor materials; computers, servers, data-processing units, periph- erals, storage, adapters, and related parts; PCAs for automatic data-processing machines; smart- phones; network switching and routing equipment; solid-state storage; flat-panel display modules and certain monitors; discrete semiconductors, LEDs, integrated circuits, and related parts; semicon- ductor fabrication, test, inspection, and metrology equipment and parts; and sintered neodymium-iron- boron magnets. Certain battery waste and scrap are also excluded. USTR cited limited substitutability for semicon- ductor tools and insufficient commercially reasonable domestic supply for certain battery waste and scrap. But the operative question remains classification. The gaps may matter more to assembly opera- tions. There is no broad unrestricted universal exclusion for bare PCBs, capacitors, resistors, most relays, switches, terminal blocks and connectors, general cable assemblies, ordinary transformers and power supplies, or generic printed circuit assemblies. Many of the product exclusions apply only to civil-aircraft goods. Country schedules add narrower relief. The clearest example of the electronics supply chain is the UK's medical-electronics sector, including diag- nostic, monitoring, imaging, and therapeutic equip- ment, as well as associated PCAs and parts. Several schedules also cover selected glass-fiber fabrics or scrap of gallium, germanium, indium, niobium, or vanadium. Taiwan and Malaysia do not receive broad special exclusions for mainstream electronics. Section 232 Exclusions and Caveats Goods actually covered by specified Section 232 "national security" measures, including relevant steel, aluminum, copper and derivatives, vehicles and parts, wood products, and semiconductor arti- cles, are excluded from the new tariffs. Being "actu- ally covered," however, is key. Under the April 2026 metals framework, many "derivative" products fall outside the metals tariff when covered metal is 15% or less of total weight. Consider a mixed-material control module on a derivative list: If covered metal does not exceed the threshold, it may escape Section 232, but then lose the Section 301 exclusion and pick up the forced- labor tariff unless another exclusion applies. The bills of materials and weight records are, therefore, critical documentation in determining which tariff applies. Test both sides of the inter- action rather than assuming that appearing on a Section 232 list ends the analysis. The USMCA Opportunity Canada- or Mexico-origin goods that entered free of duty under USMCA are excluded from the new duties. As I've emphasized in some of my earlier articles, USMCA qualification is an operational tool, not a checkbox. General Note 11(p) could be an especially useful route for a defined group of IT goods imported from Canada or Mexico. It specifies computers and data-processing machines and units, storage, certain displays, ADP parts, LAN parts, monitor and projector parts, and computer power supplies. The opportunity is classification-specific, does not cover all electronics, and requires a proper USMCA entry. Nonqualifying Canadian or Mexican goods remain exposed absent another exclusion. The IOR Pressure Point Along with new tariffs comes enforcement. On June 3, the White House issued an executive order directing tighter importer-of-record (IOR) eligibility, stronger bonding or domestic-asset requirements, Tariff Terminal