ACM Research Inc

Item 1A. Risk Factors

Except as set forth below, the

There were no material changes to the risk factors discussed in Item 1A. Risk Factors of Part I in our Annual Report. In addition to the other in formation set forth in this report, you should carefully consider those risk factors, which could materially affect our business, financial condition and future operating results. Those risk factor the fiscal year ended December 31, 2024, as are not the only risks facing our company. Additional risks mended and uncertainties not currently known to us or that we currsupplemently deem to be immaterial also may have a material adverse effect on our business, financial condied by the information and operating results.

We may be subject to risks related to recent U.S. tariffs on the semiconductor industry

On April 5, 2025, the Trump administration imposed sweeping new reciprocal tariffsin Item 1A. Risk Factors of Part II in our Quarterly Report on most imported items, including a baseline rate of 10% on most countries. This baseline 10% rate was scheduled to increase on various countries on April 9, 2025, but was subject to a 90-daForm 10-Q for the quarterly pause for the administration to negotiate agreements with affected countries. However, full reciprocal tariffs did go into effect on China, which currently stand at 125%. Earlier 20% tariffs against China imposed under an executive order targeting the fentanyl import trade stack on top of the reciprocal tariffs, such that China is subject to 145% tariffs. Additional 25% tariffs may also apply to goods from Chinaeriod ended March 31, 2025. In addition to the other information set forth in that are subject to earlier duties imposed by the first Trump Administration under Section 301 of the Trade Act of 1974.

Semiconductors are currently exempted from coverage of the reciprocal tariffs (including the 125% reciprocal tariffs on China). This exemption was later clarified to include certain electronic items incorporating semiconducis report, you should carefully consider those risk factors. However, this exemption may be temporary as the U.S. Department of Commerce on April 1, 2025, initiated an investigation under Section 232 of the Trade Expansion Act of 1962 to assess the national security implication of imports of semiconductors, semiconductor manufacturing equipment, and derivative products. Under Section 232, the Department of Commerce has 270 days (by December 27, 2025) to complete its investigation, although the Trump administration has indicated a desire to finish on a timeline of a few months. After that, the administration may take measures to address national security concerns, such as imposing specific tariffs on semiconductors or taking other , which could materially affect our business, financial condition and future operating results. Those risk factions to curtail imports.

As a company that designs and manufactures equipment and products used in ors are not the semiconductor industry, we are exposed to ronly risks arisifacing from these proposed tariffs due to our reliance on global supply chains. Tariffs may also disrupt the globour company. Additional electronics supply chain, as semiconductors are critical components in products such as servers, smartphones, and automotive systems. Increased costs for our customers could lead to reduced demand for our products, particularly in price-sensitive markets, which may adversely affect our revenue and market share. Furthermore,risks and uncertainties not currently known to us or the Section 232 national security investigation into semiconductors (as well as the overall tariff regime) introduces additional uncertainty, as it could result in broader trade restrictions or changes to import policies that further impact our ability to source rawat we currently deem to be immaterial also may have a materials and sell our products adverse efficiently.

The uncertainty surrounding the current semiconductor Section 232 investigation, its implementation timeline, and other issues, combect on our busined with the potential for retaliatory trade actions from key markets like China, poses a significant risk to our finss, financial condition, results of operations, and competitive position in the global market and operating results.