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            Medical Goods

On September 24, 2025, the U.S. Department of Commerce (“Commerce”) issued an unpublished [1] notice, regarding a Section 232 investigation into the import and supply chains covering personal protective equipment (“PPE”), medical consumables, medical equipment, and medical devices. According to the unpublished notice, the investigation is focused on specifically:

  • PPE: Surgical masks, N95 respirators, gloves, gowns, and other related medical parts and components.
  • Medical consumables: Medical/surgical instruments like syringes, needles, infusion pumps, forceps, scalpels; medical/surgical supplies, like intravenous bags, tracheostomy tubes, anesthesia equipment, gauze/bandages, sutures, diagnostic and laboratory reagents; and other related parts and components.
  • Medical equipment: Broadly referred to as durable equipment, tools, and machines used to support healthcare patients such as wheelchairs, crutches, and hospital beds.
  • Medical devices: Pacemakers, insulin pumps, coronary stents, heart valves, hearing aids, robotic and non-robotic prosthetics, blood glucose monitors, orthopedic appliances, electromedical apparatus, electrosurgical apparatus, x-ray apparatus, respiratory machines, and MRI machines.

Comments on the inclusion of the above are due within twenty-one (21) days after publication of the notice. Assuming the notice is published, as scheduled, on September 26, 2025, comments would be due October 17, 2025.

            Machine Tools and Industrial Robots

Similarly, on September 24, 2025, Commerce issued an unpublished [2] notice regarding a Section 232 investigation into the national security implications of imports of robotics and industrial machinery. According to the notice, the investigation includes robots and programmable, computer-controlled mechanical systems, such as Computer Numerical Controlled (CNC) machining centers, turning and milling machines, grinding and deburring equipment, and industrial stamping and pressing machines. The investigation also includes automatic tool changers, jigs and fixtures, and machine tools for cutting, welding, and handling work pieces.

Comments on the inclusion of the above are due within twenty-one (21) days after publication of the notice. Assuming the notice is published, as scheduled, on September 26, 2025, comments would be due October 17, 2025.

We are continuing to monitor developments and will provide additional updates as they arise.

[1] The official notice is scheduled to be published on September 26, 2025.

[2] The official notice is scheduled to be published on September 26, 2025.