ARTICLE
22 April 2025

Notice Of Request For Public Comments On Section 232 National Security Investigation Of Imports Of Pharmaceuticals And Pharmaceutical Ingredients

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In an era marked by global unrest, regulatory complexities, and a shifting market landscape, companies must remain diligent in their trade compliance procedures and stay apprised of changes in the law.
United States International Law

In an era marked by global unrest, regulatory complexities, and a shifting market landscape, companies must remain diligent in their trade compliance procedures and stay apprised of changes in the law.

TC Trade Alerts will serve as a central resource for identifying the policy changes, executive orders, and necessary information and context regarding government actions affecting international trade.

See below for more information on the last TC Trade Alerts. If you have any questions about how this affects your business, please don't hesitate to contact one of our attorneys.

Additional Resources

Trade Compliance Handbook | Checklists of Foreign Countries Subject to Sanctions | Our International Trade Practice

THOMPSON COBURN TRADE ALERT – IMPORTS
HEADLINE Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Pharmaceuticals and Pharmaceutical Ingredients
DATE April 16, 2025
AGENCY Department of Commerce; Trump Administration
EFFECTIVE DATES Deadline to Submit Comments in Docket No. 250414-0065 – May 7, 2025 (21 Days after Publication Date)
BACKGROUND On April 1, 2025, the Trump Administration directed the Secretary of Commerce to conduct a 232 investigation into pharmaceuticals, pharmaceutical ingredients, and their derivative products to determine whether such imports impair the national security of the United States.
DETAILS The Department of Commerce's Bureau of Industry and Security is seeking written comments, data, and information related to the national security impacts of pharmaceuticals, pharmaceutical ingredients, and their derivative products.

The Department is specifically interested in receiving comments and information regarding the following areas:

  • Current and future demand for pharmaceuticals and pharmaceutical ingredients
  • Ability of domestic production of pharmaceuticals and pharmaceutical ingredients to meet demand
  • Role of foreign supply chains, particularly from major exporters, in meeting U.S. demands
  • Concentration of U.S. pharmaceutical and pharmaceutical ingredients imports from a small number of suppliers and the associated risks
  • Impact of foreign government subsidies, overcapacity, and predatory trade practices on domestic industry competitiveness
  • Impact of low pharmaceutical and pharmaceutical ingredients prices due to unfair trade practices and state-sponsored overproduction
  • Risks from potential export restrictions by foreign nations
  • Feasibility of expanding domestic pharmaceutical production to reduce dependence on imports
  • Impact of current trade policies on domestic pharmaceutical production and whether additional measures, including tariffs or quotas, are necessary to protect national security

Please refer to the Notice linked below for filing instructions. Comments can be submitted electronically at www.regulations.gov, ID: BIS-2025-0022, and all comments should refer to XRIN 0694-XC120

BASIS Section 232 of the Trade Expansion Act of 1962; part 705 of the National Security Industrial Base Regulations (15 CFR parts 700 through 709)
CITE Federal Register: Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Pharmaceuticals and Pharmaceutical Ingredients

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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