On September 2, 2025, the Department of Commerce (Commerce) initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of personal protective equipment (PPE), medical consumables, and medical equipment including devices. Interested parties may submit written comments, data, analyses, or other information to the Office of Strategic Industries and Economic Security at Commerce’s Bureau of Industry and Security (BIS) no later than October 17, 2025.

BIS is particularly interested in comments addressing:

  1. The current and projected demand for PPE, medical consumables, and medical equipment, including devices, in the United States;
  2. The extent to which domestic production of PPE, medical consumables, and medical equipment, including devices, can meet domestic demand;
  3. The role of foreign supply chains, particularly of major exporters, in meeting U.S. demand for PPE, medical consumables, and medical equipment, including devices;
  4. The concentration of U.S. imports of PPE, medical consumables, and medical equipment, including devices, from a small number of suppliers or foreign nations and the associated risks;
  5. The impact of foreign government subsidies and predatory trade practices on the competitiveness of PPE, medical consumables, and medical equipment, including devices, manufacturers, in the United States;
  6. The economic impact of artificially suppressed prices of PPE, medical consumables, and medical equipment, including devices, due to foreign unfair trade practices and state-sponsored overproduction;
  7. The potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over supplies of PPE, medical consumables, and medical equipment (including devices);
  8. The feasibility of increasing domestic capacity for PPE, medical consumables, and medical equipment, including devices, to reduce import reliance;
  9. The impact of current trade policies on domestic production of PPE, medical consumables, and medical equipment, including devices, and whether additional measures, including tariffs or quotas, are necessary to protect national security;
  10. The potential for foreign control or exploitation of supply chains for PPE, medical consumables, and medical equipment, including devices;
  11. The ability of foreign persons to weaponize the capabilities or attributes of foreign-built PPE, medical consumables, and medical equipment, including devices; and
  12. Any other relevant factors.

Comments must be submitted via the federal rulemaking portal at www.regulations.gov. The Docket ID for the request for public comments regarding this Section 232 investigation is BIS-2025-0258, and submitters must refer to XRIN 0694-XC134 in all comments. In initiating this investigation, the Secretary of Commerce must, within 270 days, submit a report to President Donald Trump with findings and recommendations on potential actions to mitigate any national security threats. While the Section 232 process allows for public hearings, it is unknown at this time whether Secretary of Commerce Howard Lutnick will direct such a process.

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Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.