Commerce Launches 232 Investigations into Medical Supplies, Robotics, and Industrial Machinery

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Sep. 25, 2025
By: Austin J. Eighan

The U.S. Department of Commerce initiated two new investigations under Section 232 of the Trade Expansion Act of 1962, as amended, to determine whether imports of medical supplies or robotics and industrial machinery threaten national security. Commerce opened the investigations on September 2 and has 270 days (i.e., until May 30, 2026) to present its findings to the President.

The medical supplies under investigation include personal protective equipment (PPE), medical consumables, and medical equipment including devices. Commerce provided a list of potential items covered under these broad product categories:

• PPE – surgical masks, N95 respirators, gloves, gowns, and related medical parts and components;
• Medical consumables – medical/surgical instruments (e.g., syringes, needles, infusion (IV) pumps, forceps, scalpels); medical/surgical supplies (e.g., intravenous (IV) bags, catheters, tracheostomy tubes, anesthesia equipment, gauze/bandages, sutures, diagnostic and laboratory reagents); and related medical parts and components;
• Medical equipment – carriages and 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 (e.g., computed tomography scanners, magnetic resonance imaging machines); electrosurgical apparatus; x-ray apparatus/other radiation equipment; respiratory machines (e.g., ventilators, respirators, oxygen apparatus); and MRI machines.

The investigation covering robotics and industrial machinery similarly spans a wide array of products, including:

• Robotics and industrial machinery – robots and programmable, computer-controlled mechanical systems; CNC machining centers; turning and milling machines; grinding and deburring equipment; industrial stamping and pressing machines; automatic tool changers; jigs and fixtures; machine tools for cutting, welding, and handling work pieces; and application-specific specialty metalworking equipment used to treat, form, or cut metal (e.g., autoclaves and industrial ovens, metal finishing and treatment equipment, EDM machinery, and laser and water-cutting tools and machinery).

Pharmaceuticals, such as prescription drugs, over-the-counter drugs, biologics, and specialty drugs, as well as unmanned aircraft systems are not included as they are covered by other Section 232 investigations.

The Secretary of Commerce tasked the Bureau of Industry and Security (BIS) with the reviews, which will focus on supply chain vulnerabilities, foreign trade practices, and the capacity of U.S. industry to meet domestic demand. Based on BIS’s determination, the President will decide whether these items should face additional tariffs, quotas, or other “additional measures” upon import.

BIS encourages interested parties to submit written comments by October 17 via the Federal rulemaking portal under docket number BIS-2025-0258 for medical supplies and BIS-2025-0257 for industrial machinery, referencing XRIN 0694-XC134 and XRIN 0694-XC138 respectively.

If your company has concerns about the scope of the investigations or would like to file a comment, please reach out to one of our attorneys at Barnes, Richardson & Colburn.