Selling PC Parts in 2026: Section 301, Section 232 Semiconductor Tariffs, Expiring Exclusions and Related-Party Pricing
Chinese-origin graphics cards and motherboards mostly sit on Section 301 List 3 at 25%, some under temporary exclusions; an extra 12.5% applies from July 24, 2026; Section 232 covers only certain advanced chips; IEEPA duties can be refunded. A related factory's price drives both duty and U.S. income tax, and §1059A caps inventory basis at customs value.
Selling Chinese-origin PC parts in 2026 means pricing four tariff layers into landed cost: 25% under Section 301 List 3 (with some graphics cards, motherboards and cases temporarily excluded), an additional 12.5% Section 301 duty from July 24, 2026, a Section 232 semiconductor tariff that so far covers only a narrow set of advanced chips, and IEEPA tariffs that the Supreme Court stopped and that can now be refunded. Duty belongs in inventory cost, and the price a Chinese factory charges its U.S. subsidiary drives both duty and U.S. income tax; under §1059A, tax inventory basis generally can't exceed customs value.
Which tariff layers apply to PC parts now?
Section 301 (the 2018 lists): still in effect as of November 2026. Lists 1 to 3 generally carry 25% and List 4A 7.5%. Computer parts such as graphics cards and motherboards (HTS 8473.30 and others) are mostly on List 3; List 4B, which covered laptops and desktops, never took effect. A January 2026 Court of International Trade decision confirmed that a mining card classified under 8473.30.1180 owed the 25% Section 301 duty and didn't fit the graphics-card exclusion's description.
Exclusions: the 178 exclusions USTR extended, including some graphics cards, motherboards and cases, run under the December 1, 2025 Federal Register notice to around November 9–10, 2026. Some reports say USTR extended them again on November 6, 2026 to January 9, 2027; we had not confirmed that in an official USTR notice when writing, so ask your broker before placing orders. An exclusion only covers goods that match its description exactly; a near miss on classification or description means no exclusion.
Section 301 (2024 increases): semiconductors (HTS 8541 and 8542) at 50% from 2025, and non-EV lithium-ion batteries at 25% from 2026. Bare chips and batteries imported separately need a close look.
Section 301 (forced-labor action): from July 24, 2026, an additional 12.5% on Chinese-origin goods, stacked on existing duties. Whether the 2018-list exclusions also cover this layer should be confirmed from the action's notice and with your broker.
Section 232 (semiconductors): from January 15, 2026, 25% on certain advanced computing chips and derivative products, with chips in the class of the NVIDIA H200 and AMD MI325X as examples. Exemptions include chips for U.S. data centers, repairs and replacements, research and development, startups and non-data-center consumer applications. Ordinary consumer components are generally outside this phase. Commerce was due to report on data center chips by July 1, 2026; as of November 2026 we had found no broader second phase in effect.
IEEPA tariffs: the Supreme Court ruled on February 20, 2026 that IEEPA doesn't authorize tariffs. Duties paid can be refunded through the CAPE function in CBP's ACE system (from April 20, 2026), and only the importer of record or its broker can file.
Origin: follows substantial transformation, not the shipping point. Goods originating in Taiwan or Vietnam aren't subject to the China Section 301 duties but face other tariffs; see the Amazon FBA guide.
How duty flows into cost and profit
Duty, inbound freight and brokerage are capitalized into inventory and deducted through cost of goods sold when the goods sell, not in the year the duty is paid. Duty on goods still sitting in SBN warehouses at year-end stays in ending inventory.
When an IEEPA refund arrives, the part tied to goods already sold generally counts as income or reduces cost of goods sold for that year; the part tied to goods still on hand reduces inventory cost. If a forwarder imported under DDP, the refund is in the forwarder's name and you can only settle with it under your contract.
Example (hypothetical numbers, to show the method)
A Chinese-origin CPU cooler is bought by a U.S. subsidiary from its related factory at $18 and entered at $18. Assume both the 25% and 12.5% layers apply, 37.5% in total, so duty is $6.75 a unit. On Newegg it sells for $59.99: the 10% computer hardware referral fee is $6.00, the order fee $0.29 and SBN fulfillment for a 3 lb large standard-size unit $7.82. After freight, storage, advertising, returns and warranty, profit is about $12.13 a unit.
Raise the purchase price to $22: duty rises by $4 × 37.5% = $1.50 a unit, while the U.S. company's profit falls by $4 and its federal tax by $4 × 21% = $0.84. Net, about $0.66 more per unit, before counting extra profit and tax in China.
Enter at $14 but pay $18 in the books: duty falls by $1.50 a unit, but under §1059A, inventory basis from a related-party import generally can't exceed the customs value, so the extra $4 isn't deductible as cost, and customs undervaluation risk comes with it.
The takeaway: when duty rates are high, the usual transfer-pricing lever runs the other way. Set one arm's-length price under §482, use the same number for customs, the books and Form 5472, and keep the pricing documentation.
Platform costs to include in the price
Beyond duty, a Newegg PC parts seller should budget referral fees (10% for computer hardware, 8% for consumer electronics), $0.29 per order, membership fees (Professional $49.95, Enterprise $99.95 a month), peak SBN storage ($2.40 per cubic foot in October–December) and long-term storage after a year ($7.00), returns (Newegg allows restocking fees of up to 15% on opened graphics cards, motherboards and some other categories, but return rates run high), and the reserved balance Newegg holds against returns and chargebacks, which affects cash flow but isn't an expense.
Related factory and U.S. subsidiary: annual filings
The U.S. subsidiary files Form 1120 with Form 5472, reporting purchases from, payments to and loans with its parent or related factory, at $25,000 per missed form. Dividends to the Chinese parent carry withholding, generally 10% under the U.S.–China treaty, reported on Forms 1042 and 1042-S. The pricing file between parent and subsidiary supports both the customs and income tax sides; see the Chinese parent and U.S. subsidiary guide.
How we can help
YCL handles the tax side: modeling how related-party prices affect duty and U.S. income tax, preparing pricing documentation, booking duty and refunds into inventory correctly, and filing Form 1120 and 5472 each year. HTS classification, whether an exclusion applies and origin rulings are for customs brokers and lawyers. For Newegg's full fees, SBN and entity choices, see the Newegg guide; for AI hardware tariff layers, see the AI companies going global guide. Book a free 15-minute call or reach us on WeChat at YCLUSA.
Sources
USTR: Section 301 investigations, China
Federal Register: Notice of extension of certain exclusions (December 1, 2025)
[USTR: Section 301 Modifications Determination (September 12, 2024)](https://ustr.gov/sites/default/files/Section%20301%20Modifications%20Determination%20FRN%20(Sept%2012%202024)%20(FINAL).pdf)
IRS: Instructions for Form 5472
Last checked: November 9, 2026
This article is general tax information, not tax, legal or customs advice for any individual or company. Tariffs change quickly; CBP and USTR notices and your broker's advice decide.
Questions this article answers
What duty applies to Chinese-made graphics cards and motherboards now?
As of November 2026, most are on Section 301 List 3 at a general 25%, with some covered by the 178 exclusions USTR extended; an additional 12.5% Section 301 duty has applied to Chinese-origin goods since July 24, 2026. The HTS code, the exclusion's description and your broker's advice decide.
Does the Section 232 semiconductor tariff hit ordinary PC parts?
Phase one, from January 15, 2026, adds 25% only on certain advanced computing chips and derivative products, with exemptions including U.S. data centers, repairs, R&D and consumer applications, so ordinary consumer components are generally outside it. As of November 2026 we found no broader second phase in effect.
Should a related factory charge its U.S. subsidiary more to cut U.S. tax?
Not when duty is high. In the example, with 37.5% duty, each $4 increase adds $1.50 of duty but saves only $0.84 of federal corporate tax. Entering goods at a low customs value while paying more in the books fails too, because §1059A generally caps inventory basis at customs value. Set one arm's-length price and use it for customs, the books and Form 5472.
How is an IEEPA tariff refund booked?
When received, the part tied to goods already sold generally counts as income or reduces that year's cost of goods sold; the part tied to goods still on hand reduces inventory cost. Only the importer of record or its broker can claim through CBP's CAPE function, so if a forwarder imported, the refund is in its name.
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