Comment on Section 232 Investigation of Imports of PPE and Medical Equipment

Today, I filed a comment to the Department of Commerce regarding the Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices

October 17, 2025

VIA ELECTRONIC FILING

Ms. Julia A. Khersonsky

Deputy Assistant Secretary for Strategic Trade

Bureau of Industry and Security

U.S. Department of Commerce

1401 Constitution Ave., NW

Washington, DC 20230

Re: 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 (Docket No. 250924-0160) XRIN 0694-XC134

Dear Ms. Kheronsky,

During the COVID-19 pandemic, Americans realized just how closely intertwined our supply chains are with the People’s Republic of China. This became particularly apparent in the rush for masks and other PPE, which were often in short supply. Even today, half a decade later, around 90 percent of American PPE comes from China. And in 2024, the United States imported over $40 billion more than it exported when it came to medical goods, including PPE. As proud supporters of reshoring American industry and decoupling from China, we support all efforts to ensure that Americans will have the tools and products necessary for a safe and secure society. To that end, we fully support placing tariffs on Chinese-specific goods in order to spur domestic production.

However, we believe that a Section 232-tariff on all “personal protective equipment (PPE), medical consumables, and medical equipment including devices” would be a mistake. As opposed to China-specific tariffs, Section 232 places tariffs on everyone. And in this specific case, such an action is unnecessary.

An overwhelming majority of medical equipment used in America – fully 70 percent – is manufactured in the United States, according to BMI, a Fitch Solutions company. This is an extremely healthy sector in our economy. In fact, it is so healthy that our medical equipment sector is responsible for 40 percent of the entire global medtech market. In 2023, the United States exported over $100 billion in medical equipment technologies. In short, the American medical equipment market is extremely strong.

Roughly 30 percent of globally-produced medical equipment is manufactured by allies such as the European Union and Japan.

Before this year, American-European Union trade was clearly unbalanced in favor of the latter; in 2024, America had a trade deficit of over $235 billion with the EU. Seeking to change this, President Donald Trump’s tariff strategy forced the EU to the negotiating table and produced a phenomenal deal which eliminated all European tariffs on American goods, secured a baseline 15 percent tariff on all incoming European goods, and secured hundreds of billions in investment. Had the European Union not agreed to this deal, we would have been among the first to support vigorous tariffs on European goods to ensure a fair deal for Americans. Now that they have agreed to the arrangement, however, we believe that further tariffs of this sort are unnecessary.

The same situation exists for Japan. Though they were resistant to more fair trade arrangements at first, President Trump convinced them otherwise, and now they too have agreed to a trade proposal which includes a 15 percent baseline tariff on Japanese goods and $550 billion in investment.

A sweeping Section 232 tariff could not only upset the carefully-constructed domestic medical equipment industry, but it could also put these successes at risk. We are strong proponents of both vigorous, effective tariffs and strong domestic industry, and would regret seeing both injured in one fell swoop.

The Trump administration’s mainstreaming of tariffs and America First economics is a tremendous development for the American people and should continue. But, respectfully, we believe that Section 232 tariffs here should not be a part of that strategy.

Sincerely,

Aiden Buzzetti

President

The Bull Moose Project