AdvaMed Request for Tariff Exclusions for Medical Technology Products
May 5, 2020
The Advanced Medical Technology Association (AdvaMed) has consistently indicated that the United States should not be imposing tariffs on medical technology. USTR’s moves in that direction are welcome.
We are grateful to USTR for its recent decision to grant exclusions for a range of personal protective equipment (PPE) imports from China. This action could help lower the cost of importing face masks, examination gloves, surgical drapes, and gowns that are essential to combatting coronavirus here in the United States.
We appreciate the opportunity to request additional tariff exclusions, as indicated in the March 23, 2020 Federal Register notice: FR 2020 – 06285. The attached lists of products meet the criteria specified in the FR notice, as these are products – both finished products and parts and components used in equipment manufactured in the United States — relate to COVID-19. Tariff exclusions should be provided to parts and components, as well as finished products, because both categories play an important role in strengthening the US response to the COVID-19 crisis by expanding the supply of equipment available to healthcare providers.
We believe Section 301 tariffs on all of these products should be removed without a fixed termination date or, of that is not possible, at least until one year after the World Health Organization declares the end of the coronavirus pandemic. We also request that where any product on the AdvaMed list already has an exclusion in force, USTR extend the exclusion for that product with no fixed termination date or, if that is not possible, for at least a year after the WHO declares the end of the pandemic. We stress that in considering tariff relief the larger significance for removal of tariffs should be improving the supply chain’s ability to service all care levels more broadly in response to the totality of needs, not just only for COVID
patients. When foreign suppliers have a choice of where to ship, the cost of sending such products to U.S. patients should be competitive with other countries that do not impose Section 301 tariffs. Inventories will need time to rebuild after COVID-19 has ended.
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