On September 24th, the U.S. Department of Commerce launched a Section 232 National Security Investigation into medical product imports. Comment on this investigation is currently open under Section 232 Medical PPE and Equipment (Document ID BIS-2025-0258-0001) at Regulations.gov.

The model letter below outlines our core arguments against potential 232 tariffs on medical products and encourages the Administration to use other mechanisms to bolster domestic manufacturing of medical products. We urge industry leaders to comment by the deadline: October 17, 2025.

Step 1: Prepare Your Comments

  • Personalize And Localize The Impact: Your comments should clearly explain how potential tariffs on medical products would affect your business. This is also an opportunity to demonstrate the impact existing medical product tariffs have had on your operations. You are your own best advocate, and your experiences and observations are the most persuasive.
  • Emphasize The Global Context: For purposes of public comment, it is helpful to provide examples of the unintended consequences tariffs have on the healthcare supply chain.

Step 2: Navigate To Regulations.Gov

The button below will take you directly to the comment submission page for “Section 232 Medical PPE and Equipment (Document ID BIS-2025-0258-0001).

Comment Submission Page

  • On the left-hand side, click the large blue button labeled “Comment.” You will then advance to a new webpage titled “Write a Comment.”
  • Under the red Comment prompt, type a brief description of your comment “[Company] comments on Section 232 investigation”
  • Next, upload a copy of your comments.

Step 3: Review And Submit

Click the blue “Submit Comment” button at the bottom of the page. Be sure to provide your email and check the opt-in box below to receive confirmation of your submission.


Model Letter For HIDA Members

We encourage you to use this text to guide your own original letter that includes specific details of your business and its role in the medical supply chain. Please do not copy and paste the letter.

Download (Microsoft Word)

[Insert Company Letterhead]

FR Doc: BIS-2025-0258
October XX, 2025
By Electronic Submission

Julia A. Khersonsky
Deputy Assistant Secretary for Strategic Trade
Bureau of Industry and Security
Department of Commerce
1401 Constitution Ave. NW
Washington, DC 20230

Re: Notice of Request for Public Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices

Dear Ms. Khersonsky:

On behalf of [Company], I offer this response to the Department of Commerce’s request for comments on the Section 232 national security investigation on imports of personal protective equipment (PPE), medical consumables, and medical equipment.

[Describe your company. How many employees do you have? What customers do you serve? Have tariffs forced you to cut services or delay investments? Do you manufacture or distribute domestic products you can spotlight?]

Healthcare distributors are an essential link in the medical supply chain for small-market and rural healthcare providers – the very hospitals, doctors' offices, and nursing homes that are under pressure from other economic and policy changes in healthcare. Margins in healthcare distribution are small, and the cost increases tariffs impose on medical products cannot be absorbed forever. Many healthcare distributors are operating at a loss due to tariffs.

The right tariff policies can help domestic manufacturing. Tariffs levied during President Trump's first term have had a positive effect. The pandemic prompted the medical supply chain to further reassess an over-reliance on products from China. In subsequent years, medical manufacturers have moved out of China to other countries around the globe.

The wrong tariff policies will strain the medical supply chain. Country-specific reciprocal tariffs on imported raw materials make it more expensive to continue medical product manufacturing in the United States. Ironically, more tariffs would harm domestic manufacturers more than they would help. Any additional tariffs from Section 232 would make the medical supply chain unsustainable. Without time to adjust, patient care would be put at risk.

Thank you for the opportunity to comment as part of this investigation. [Company] greatly values the Administration’s ongoing commitment to supporting a resilient medical supply chain to protect our national security.

Sincerely,

[Your Name]
[Your Title]
[Your Organization's Name]

Contact:

Wyeth Ruthven

Wyeth Ruthven
Director, Congressional & Public Relations
703-838-6128
ruthven@hida.org