US: Proposed Tariff Rate to Impact Clinical Supplies Imported from China

The Office of the U.S. Trade Representative (USTR) published a list of products that are subject to the proposed tariff increase on goods imported from China[i]. The targeted tariff will impose an additional 25% tariff rate on approximately 1,300 products from China.

Included in the list of products affected by the 25% tariff increase are several medicines, vaccines, biologic products, API and certain clinical kits and devices. The listed products are identified by their 8-digit level HTS code and include products in Tariff Heading 28, 29, 30 and 90.

Since the Uruguay Round of trade negotiations of 1986-1994, pharmaceutical products imported into the U.S. are granted duty-free entry under the “zero-for-zero initiative.” However, if the proposed tariff action moves forward, companies importing pharmaceutical products and clinical supplies will begin paying Customs duties on the products listed by the USTR.

The public comment period, during which interested parties may submit comments to the USTR regarding the proposed tariff action, remains open until May 11, 2018. The USTR requests that commenters specifically address whether imposing increased duties on a particular product would cause disproportionate economic harm to U.S. interests, including small- or medium-size businesses and consumers.

Marken continues to monitor this proposed action closely and the impact it may have on the clinical supply chain. Questions can be sent to Marken’s trade compliance team at


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