Premier Weighs in on Section 232 Investigation into Medical Devices and Tariffs

Premier submitted comments on the Section 232 investigation into imports of PPE and other medical devices. The Department of Commerce launched the formal national security investigation to potentially open the door for future tariffs.

In its comments, Premier recognized the value that the thoughtful and targeted use of tariffs can provide to supply chain resiliency in the long-term but warned that material increases in tariffs on healthcare supplies coupled with rapid implementation timelines can result in unintended consequences that increase costs and shortages in the short-term. Premier underscored to the Administration that any unified trade policy on healthcare products must ensure that overarching supply chain resiliency goals are met while minimizing the downstream impact to patient care. Specifically, Premier urged the Department of Commerce to:

• Develop a targeted approach to tariff implementation that considers products deemed essential by the Food and Drug administration and Department of Defense separately from all other healthcare products due to their direct impact on national security;
• Provide a slow and steady glidepath approach to tariff implementation to help ensure that both manufacturers and healthcare providers have sufficient time to respond and adapt to new tariffs while continuing to deliver essential healthcare services effectively;
• Clarify if specific categories are or are not subject to tariffs including clear definitions for the components of devices subject to tariffs;
• Study the impacts of tariffs on the healthcare supply chain to ensure that tariffs are meeting the end goal of spurring domestic ingenuity and identify any unintended consequences, such as increases in costs or shortages, necessitating swift remediation to prevent patient harm; and
• Augment supply chain resiliency efforts through additional mechanisms such as tax incentives supporting domestic manufacturing and the creation of trusted trade partnerships for near-shoring.