THOMPSON COBURN TRADE ALERT – IMPORTS
HEADLINE	Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Medical Products
DATE	September 25, 2025
AGENCY	Department of Commerce; Trump Administration
EFFECTIVE DATES	Deadline to Submit Comments in Docket No. 250924-0160 – October 17, 2025 (21 Days after Publication Date)
BACKGROUND	The Department of Commerce revealed that it initiated an investigation three weeks ago, on September 2, 2025, to determine the effects on national security of relevant medical imports discussed further below.
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 personal protective equipment (PPE), medical consumables, and medical equipment including devices (“Medical Products”).   The Department is specifically interested in receiving comments and information regarding the following areas: • Current and future demand for Medical Products in the U.S.; • Ability of domestic production to meet domestic demand; • Role of foreign supply chains, particularly from major exporters, in meeting U.S. demand; • Concentration of U.S. imports of Medical Products from a small number of suppliers or foreign nations and the associated risks; • Impact of foreign government subsidies, and predatory trade practices on domestic industry competitiveness; • Economic impact of artificially suppressed prices due to unfair trade practices and state-sponsored overproduction; • Risks from potential export restrictions by foreign nations; • Feasibility of expanding domestic production to reduce dependence on imports; • Impact of current trade policies on domestic production and whether additional measures, including tariffs or quotas, are necessary to protect national security; • Potential for foreign control or exploitation of supply chains; • Ability of foreign persons to weaponize the capabilities or attributes of foreign-built Medical Products.     The specific Medical Products listed include a wide range of products, e.g.: • PPE (surgical masks, N95 respirators, gloves, gowns) • Medical consumables (syringes, IV bags, gauze/bandages, sutures) • Medical equipment (wheelchairs, crutches, hospital beds) • Medical devices (pacemakers, insulin pumps, hearing aids, orthopedic appliances, electromedical apparatus, MRI machines) We note that many of the products listed in the Notice have been specifically designated by CBP as qualifying for duty-free preferential treatment under the Nairobi Protocol for “Articles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons.” The Notice did not address future Chapter 98 application for this Section 232 investigation.   Thompson Coburn is ready to provide assistance to anyone who may wish to submit comments.   Please refer to the Notice linked below for filing instructions. Comments can be submitted electronically at www.regulations.gov, ID: BIS-2025-0258, and all comments should refer to XRIN 0694-XC134.
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: Federal Register :: Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices

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