Tariff and customs classification
Tariff and customs classification for technology and AI products is under active pressure from multiple directions, with the U.S. Customs and Border Protection and the Office of the United States Trade Representative both issuing binding guidance that affects how AI-enabled hardware, semiconductors, and software-bundled devices are classified at the border. The European Commission's enforcement of dual-use export controls under the EU Dual-Use Regulation adds a second classification layer that catches many tech sector importers off guard. Classification errors in this sector carry penalty exposure, not just delayed shipments.
Watch
- USTR Section 301 tariff exclusion renewals for tech components expiring on a rolling basis
- CBP ruling requests on AI-integrated hardware: classification as finished goods vs. parts
- EU Dual-Use Regulation controls on chips with military-adjacent specifications
- Harmonized System 2024 updates reclassifying certain semiconductor subcategories
- Country-of-origin determinations for AI hardware assembled across multiple jurisdictions
Recent material activity in Technology, AI & Competition
Active monitoring in place across Technology, AI & Competition. Material developments related to tariff and customs classification will appear here as they are published.