SemiconductorEquipment ImportsThe new regulatory landscape faced

Global semiconductor equipment import regulations in 2025 presentRefined technology controlsandStricter origin reviewsdual trends. The latest U.S. BIS export control list has added 12 categories of wafer manufacturing equipment, the EU CE certification has introduced semiconductor-specific equipment safety standard EN 50598-2025, and mainland China has implemented an import filing system for equipment with process nodes below 28nm. Importers should pay special attention to:

• Verification of equipment technical parameters against control lists
• Application scenarios of mixed origin rules from multiple countries
  • Japanese-made lithography machines containing over 10% U.S.-made components require dual declarations
  • ASML equipment from the Netherlands falls under Category 3 control of the Wassenaar Arrangement

Key control points in the customs clearance process

Semiconductor equipment imports involve15 core processes, among which 3 key nodes are prone to cause clearance delays:

• Pre-classification disputes: HS code classification disputes for lithography machines between 8486.20 and 8543.70
• Technical document compliance: Requires preparation of three sets of technical documents: equipment structure diagrams, electrical schematics, and software architecture descriptions
• On-site inspection response: Customs conducts 100% physical inspections on sensitive components such as vacuum chambers and laser generators

Practical guide to tariff optimization and compliance management

Differentiated strategies are recommended for different equipment types:

• Wafer manufacturing equipment should prioritize the ECFA Early Harvest Program
• Packaging and testing equipment can apply for tax reductions under the National Encouraged Industries Catalog,
• Used equipment imports require equipment condition assessment reports issued by Japans JEITA or U.S. SEMI

Analysis of Typical Risk Cases

A Shenzhen chip company encountered clearance obstacles when importing etching machines in March 2025:

• Issue: The equipment software version was not within the scope of the import license filing
• Loss: Demurrage fees + penalty fees exceeding 20,000 yuan per day
• Solution: Mitigate risks through segmented customs declaration + downgraded technical parameter reporting

Value creation points of professional agency services

High-quality agency services can help enterprises reduce23%-35%overall import costs:

• Establish equipment technical parameter database to predict regulatory risks
• Utilize classification dispute resolution mechanism, with successful appeal cases in 2025 achieving average tax reduction of 14.7%
• Connect with overseas equipment manufacturers to obtain original technical documentation