AAMC Comments on Section 232 Investigation on Imports of Medical Goods

The AAMC submitted an Oct. 17 letter (PDF) in response to a Department of Commerce request for comments on the initiation of a Section 232 investigation into the national security implications of imports of personal protective equipment, medical consumables, and medical equipment, including medical devices. Under the Trade Expansion Act of 1962 (P.L. 87-794, PDF), the Secretary of Commerce may initiate an investigation to determine if the importation of goods implicates national security concerns. Depending on the findings of the Section 232 investigation, the president may impose tariffs on goods in a sector.

In its comments, the AAMC agreed with the need for a robust and resilient supply chain with diversified sources of production, but urged against the imposition of tariffs on these broad categories of supplies and devices. The association emphasized that tariffs could result in supply shortages and price increases, which would affect patient access and safety. Finally, the AAMC recommended that if the administration were to decide to impose tariffs, they should be limited in scope and duration and include an exceptions process for critical medical devices and supplies. The department has 270 days from the Sept. 2 initiation of the investigation to submit a report to the president.