International suppliers: Finding your footing in New York’s semiconductor boom

If you supply chemicals, gases, equipment components, precision parts, packaging, logistics services or any of the dozens of other inputs a semiconductor fabrication plant requires, you have probably heard that something significant is happening in New York state.

By Jeff Davis, who coleads Barclay Damon LLP’s Semiconductor Team and co-chairs the firm’s Project Development Practice Area, With assistance from Lauryn Fulton, A Barclay Damon Associate

You are not wrong, but what you may not fully appreciate is how quickly the window to participate is closing and what it actually takes to walk through it as an international supplier.

New York is in the early stages of building one of the most consequential semiconductor manufacturing corridors in the world. Micron Technology has committed up to $100 billion to develop a chip campus outside Syracuse in Clay, New York. GlobalFoundries is expanding its operations in Malta in the Capital Region. Wolfspeed operates a silicon carbide wafer facility mid-corridor in Marcy. Together, these investments are creating a concentrated, multisite procurement environment that simply did not exist five years ago.

For international suppliers, this is not just a business opportunity—it is a strategic inflection point. But the rules for entering this market are different from what many overseas companies are accustomed to. The procurement frameworks, regulatory requirements, legal structures and incentive programs that govern participation in New York’s buildout require deliberate preparation. Here is what you need to know.

Understand the landscape before you move
New York’s semiconductor boom is not happening in isolation. It is the direct result of two interlocking policy frameworks: the federal CHIPS and Science Act (CHIPS Act), which provides tens of billions of dollars in incentives for domestic semiconductor manufacturing and supply chain development, and New York’s own Green CHIPS program, which adds another layer of state-level support designed to attract not just the fabs themselves but the ecosystem of suppliers that makes them run.

This policy context matters for international suppliers for a simple reason: The companies receiving these incentives have made commitments to domestic and regional supply chain development as conditions of receiving public funding. That creates both an opportunity and an expectation. Fabs want suppliers who can demonstrate a credible presence in the region, not just a willingness to ship from overseas.

This dynamic has a practical consequence: The time to qualify is now, during the construction and early ramp-up phase, not after production stabilizes. Supplier qualification processes and local ramp-up/buildout can be long. If you are not in those conversations today, you risk being excluded from a generation of procurement relationships.

Get your legal and regulatory house in order
The single most common mistake international suppliers make when approaching the U.S. market is underestimating the legal and regulatory lift required to operate here. This is not a criticism—it reflects a genuine difference between the U.S. business environment and that in Europe, Asia or elsewhere. But this mistake can cost you months of time and significant credibility with prospective customers.

The first priority should be establishing a proper U.S. legal entity. Operating through a foreign parent without a U.S. subsidiary creates complications in contracting, liability, tax treatment and—critically in this sector—national security review. Semiconductor supply chains are subject to heightened scrutiny under the Committee on Foreign Investment in the United States, export control regulations administered by the Department of Commerce and in some cases the requirements attached to CHIPS Act funding. These are nothing insurmountable, but they all require advance planning.

Export control compliance deserves particular attention. The Export Administration Regulations (EAR) govern the transfer of many semiconductor-related technologies, materials and equipment. If your products are classified under Export Control Classification Numbers (ECCNs) that require licenses for certain end uses or destinations, you need to understand how those obligations interact with your planned U.S. operations before you sign your first contract.

For suppliers from certain countries, there are additional layers: The CHIPS Act’s “guardrails” provisions restrict CHIPS funding recipients from expanding semiconductor capacity in “countries of concern,” and those restrictions flow through to suppliers in some circumstances. Your legal team needs to map your supply chain against these requirements before you make commitments.

Establish a physical presence and do it strategically
New York’s fabs are not simply buying from catalogs. They are building supply chain relationships with companies that can provide responsive, regionally proximate support. For international suppliers, that means some form of U.S. presence is effectively a prerequisite, whether that is a stocking warehouse, a field service operation, a technical support office, or a light manufacturing or value-added reselling facility. The good news is that New York has made significant investments in site readiness specifically to lower this barrier. The state’s FAST NY Shovel-Ready Grant Program funds infrastructure improvements—power, water, road access—at prequalified industrial sites across the state. For a supplier looking to establish a regional footprint, these pre-prepared sites can meaningfully compress the timeline and reduce up-front capital requirements.

Location matters beyond logistics. The corridor from Syracuse through the Capital Region to Mohawk Valley is where the concentration of fab activity is highest, and proximity to that corridor signals commitment. Local economic development agencies—CenterState CEO in the Syracuse region, the Center for Economic Growth in the Capital Region—are active partners for incoming suppliers and can facilitate introductions, site identification and connection to workforce pipelines.

Do not overlook the workforce dimension. New York has invested heavily in semiconductor-specific training through its community college system and State University of New York network. If your U.S. operation requires technical staff, that talent pool exists and is being actively developed. Building early relationships with regional workforce development organizations signals to your fab customers that you are a long-term partner, not a temporary opportunist.

Capture the incentives but sequence them correctly
New York’s incentives stack for semiconductor supply chain companies is genuinely significant but it requires careful sequencing to capture. Incentives are not automatic; they are negotiated commitments tied to specific investment milestones, job creation targets and performance conditions. The most common mistake is treating incentives as an afterthought rather than integrating them into your entry planning from the start.

State level
The primary vehicle for supply chain companies is the Green CHIPS / Excelsior Jobs Program administered by Empire State Development. These are pay-for-performance programs offering fully refundable tax credits tied to net new job creation and qualified capital investment. Enhanced tiers are available for semiconductor supply chain projects, and the credits can be material (the Excelsior program offers jobs credits up to 7% of wages per net new job, up to 7% for R&D expenditures, and up to 3% of qualified capital expenditures; higher tax credits are available for projects qualifying under the Green CHIPS program), but they require application and approval by the state before you begin your project, not after.

Local Industrial Development Agencies offer an additional layer that many international companies overlook. IDAs can provide property tax abatements, sales tax exemptions on construction materials and equipment, and mortgage recording tax exemptions.

For a supplier making a meaningful capital investment in a New York facility, the IDA benefits can represent millions of dollars in avoided cost. The catch: IDAs require public hearings, cost benefit analysis and annual reporting, and the IDA must pass an “inducement resolution” before construction begins and major equipment is purchased.

Federal level
The CHIPS Act offers over $52 billion in incentives to boost domestic semiconductor manufacturing, including vital support for supply chain companies. Funding is overseen by the CHIPS for America program to build a robust ecosystem for materials, equipment and advanced packaging.

The key financial and operational incentives under the CHIPS Act include:

• Manufacturing grants: $39 billion in direct subsidies is available. While initially targeting large chipmakers, eligibility explicitly includes suppliers of specialized tooling, equipment, chemicals and foundational materials.
• Advanced Manufacturing Investment Credit (Section 48D): A 35% tax credit is available for capital investments in semiconductor manufacturing facilities and the production of specialized semiconductor manufacturing equipment.
• Research and Development consortia: $11 billion is dedicated to R&D. Supply chain vendors can participate in programs via the National Semiconductor Technology Center and the National Advanced Packaging Manufacturing Program.
• Direct pay option: Taxpayers can treat the 35% investment tax credit as a direct payment against their federal tax liabilities.
• Defense funding: Additional opportunities and funding are available through the Department of Defense’s Microelectronics Commons to support prototyping and commercializing defense-oriented components.

The CHIPS Act has important considerations for suppliers that receive CHIPS Act incentives, including a prohibition for 10 years against expanding, building or significantly upgrading advanced semiconductor manufacturing facilities in countries of concern, such as China or Russia, and compliance and clawbacks if a recipient violates the foreign expansion restrictions.

The NY SMART I-Corridor initiative, funded through the federal Tech Hubs program, is a collaborative initiative across upstate New York to accelerate supply chain readiness. The Supply Chain Activation Network identifies capability gaps and connects suppliers with fab procurement teams, and innovation vouchers through NY THRIVE can connect your technical staff to university facilities and research resources. These are not financial incentives in the traditional sense, but they are relationship-building tools that can accelerate your path to vendor qualification.

Build for the long term
The suppliers who will build enduring positions in New York’s semiconductor ecosystem are not the ones who show up with a compelling sales pitch and a quick-turnaround proposal. They are the ones who demonstrate their physical presence, their quality systems, their contractual commitments, and their understanding of New York’s processes and regulations.

That means investing in relationships before you have a contract to show for it. It means engaging with regional economic development organizations not just as a path to incentives but as a way to build credibility in the community. It means being honest with prospective customers about where you are in your qualification journey and what your timeline looks like. And it means treating the legal and operational infrastructure of your U.S. entry as a strategic asset, not a compliance checkbox.

New York’s semiconductor buildout represents a generational opportunity for international suppliers. The fabs being built today will operate for decades. The supply chains being assembled now will define who participates in the next chapter of advanced manufacturing in the U.S. The companies that do the work to enter this market correctly will be positioned as indispensable partners for a very long time.

The window is open, and the opportunity to act is now.