On September 24, 2025 the Department of Commerce announced the commencement of a Section 232 investigation and a request for public comments regarding the importation of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices. This announcement follows an investigation, initiated on September 2, 2025 concerning the effects on national security of imports of personal protective equipment (PPE).
The new inquiry focuses on whether current levels of import dependence pose risks to the U.S. healthcare and industrial base, particularly during national emergencies or supply chain disruptions. While pharmaceuticals are excluded from this review, a wide range of products commonly used in healthcare settings, including masks, gloves, hospital beds, ventilators, and diagnostic equipment, fall within the investigation's scope.
This announcement is scheduled for publication on September 26, 2025 with a duration of 21 days, likely concluding on October 17, 2025. Interested parties are requested to submit written comments, data, analyses, or other information pertinent to the investigation to the Department of Commerce’s Bureau of Industry and Security (BIS), Office of Strategic Industries and Economic Security. The Department of Commerce is particularly interested in comments and information concerning:
The current and projected demand for PPE, medical consumables, and medical equipment, including devices, in the United States.
The extent to which domestic production of PPE, medical consumables, and medical equipment, including devices, can meet domestic demand.
The role of foreign supply chains, particularly of major exporters, in meeting United States demand for PPE, medical consumables, and medical equipment, including devices.
The concentration of U.S. imports of PPE, medical consumables, and medical equipment, including devices, from a small number of suppliers or foreign nations and the associated risks.
The impact of foreign government subsidies and predatory trade practices on the competitiveness of PPE, medical consumables, and medical equipment, including devices, manufacturers, in the United States.
The economic impact of artificially suppressed prices of PPE, medical consumables, and medical equipment, including devices, due to foreign unfair trade practices and state-sponsored overproduction.
The potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over supplies of PPE, medical consumables, and medical equipment (including devices).
The feasibility of increasing domestic capacity for PPE, medical consumables, and medical equipment, including devices, to reduce import reliance.
The impact of current trade policies on domestic production of PPE, medical consumables, and medical equipment, including devices, and whether additional measures, including tariffs or quotas, are necessary to protect national security.
The potential for foreign control or exploitation of supply chains for PPE, medical consumables, and medical equipment, including devices, supply chain.
The ability of foreign persons to weaponize the capabilities or attributes of foreign-built PPE, medical consumables, and medical equipment, including devices.
Any other relevant factors.
We will continue to monitor these developments as they progress. If you are interested to submit comments in this matter or have other questions related to the impact of this investigation, please contact one of the following trade professionals here.