AdvaMed outlined nearly a dozen recommendations to strengthen U.S. medtech production and exports in formal comments filed with the Commerce Department Friday in response to the Trump administration’s Section 232 investigation.
Among the recommendations are a proposal to establish a preferred trading bloc with NATO partners and allies. The industry group also called for continuing the United States-Mexico-Canada Agreement qualifying products rule for Mexico and Canada, and pursuing bilateral medtech commitments from trade partners including China and India.
The Department of Commerce in September opened an investigation into whether the current level of U.S. medtech imports has national security implications. The Trump administration has used Section 232 investigations in other sectors to impose tariffs on goods such as steel, aluminum, copper and automobiles.
AdvaMed said it submitted the comments on behalf of its more than 600 member companies.
“These policies include seeking fair and reciprocal tariff-free trade with our most important allies, aggressively addressing unfair market access barriers in specific countries, and advancing domestic regulatory reforms and procurement incentives to enhance U.S. competitiveness at home and abroad,” AdvaMed CEO Scott Whitaker wrote in the comment letter.
The recommendations include:
- Pursue reciprocal, tariff-free trade with Europe, Japan and the U.K. Establish a preferred trading bloc with NATO partners and allies to enable growth of U.S. medtech R&D and manufacturing. The approach would continue to support domestic resilience and substantial exports.
- Continue USMCA qualifying products rule for Mexico and Canada. USMCA duty-free access for qualifying products is critical to securing resilient and affordable medical technology supply chains in North America.
- Expand a qualifying rule to Costa Rica and the Dominican Republic. A USMCA-type qualifying rule for these countries would further support U.S. medtech manufacturing through additional diversification of supply chains, reduced dependence on adversarial suppliers and lower healthcare costs.
- Pursue bilateral medtech commitments from key global markets. AdvaMed members urge the administration to support U.S. medtech manufacturing by pursuing commitments from trading partners including China and India to treat American products fairly in regulatory and government procurement processes.
Because of a stringent regulatory framework, medtech manufacturers cannot easily switch suppliers or relocate production in response to market changes, AdvaMed said. Modifications to critical components or materials typically trigger lengthy validation and re-approval processes.
AdvaMed argued that tariffs that cannot be absorbed could lead to supply disruptions and cost increases and may force small and medium-sized companies out of business.
U.S. companies have been shifting resources to manage tariff costs because of the duties imposed on medtech imports since April, the industry group said. Further, R&D spending has leveled off recently due to rising material costs, regulatory challenges and economic uncertainties.
Lower tariffs and supportive policies would promote more medtech manufacturing and job growth in the U.S., AdvaMed said.
