USCBC Comments on Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices

The US-China Business Council (USCBC) welcomes the opportunity to submit comments to the Bureau of Industry and Security (BIS) on the Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices.

USCBC represents about 270 US companies that do business with China. Many of our member companies play leading roles in the medical technology sector and across related industries, including biomedical research, pharmaceutical and medical device manufacturing, healthcare logistics, and clinical applications. Collectively, these companies provide American patients with access to some of the highest-quality medical technologies in the world. The US medical technology sector contributes more than $250 billion in annual economic output and supports nearly three million manufacturing jobs nationwide. At the same time, trade in medical technologies remains strong, maintaining a trade surplus with major trading partners including China.

We appreciate the Trump administration’s efforts to investigate the national security implications of certain imported goods and to engage industry stakeholders. While approximately 70% of the medical technologies consumed in the United States are manufactured domestically, the broader supply chain leverages globally diversified production and distribution networks to ensure cost efficiency, quality, and reliability. For instance, high-value equipment and precision components are predominantly sourced from dependable trading partners such as Japan and the European Union. We are concerned that tariff actions taken on upstream components or sub-assemblies could trigger a ripple effect, affecting various stages of the supply chain, compounding the impacts of other tariffs and trade restrictions, and risking retaliation by foreign countries. As a result, the costs of intermediate goods throughout the value chain will rise sharply, imposing undue burdens on downstream distributors, healthcare providers, and patients in the United States.

In practice, tariffs lead to higher production costs and prices. Without accompanying policy incentives, companies may choose to forgo investing in and maintaining new US production capacity. Expanding tariffs to a broad range of medical products would impose additional costs on manufacturers, healthcare providers, and patients already grappling with inflation.

Instead of solely relying on tariffs, we respectfully urge BIS to clearly articulate a comprehensive strategy that enables US companies to expand their domestic manufacturing footprint while maintaining their competitiveness in international markets, including in China.

In our comments below, USCBC strives to serve as a constructive partner to the Department of Commerce as it seeks to advance policies that strengthen the United States’ medical technology sector. Our submission provides specific feedback on China’s role in the global medical device supply chain and offers recommendations from US industry stakeholders that do business with China.