Comments Filed with U.S. Commerce: Exempt Medtech from Sec. 232 Tariffs

By SBE Council at 16 October, 2025, 7:49 pm

Julia A. Khersonsky

Deputy Assistant Secretary for Strategic Trade

Office of Strategic Industries and Economic Security

Bureau of Industry and Security, U.S. Department of Commerce

1401 Constitution Avenue, NW

Washington, DC 20230

Re: Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices (Docket No. 250924-0160)

Deputy Assistant Secretary Khersonsky:

The Small Business and Entrepreneurship Council (SBE Council) is dedicated to protecting small businesses and promoting entrepreneurship. Small businesses are the backbone of the American economy, and enforcing tariffs on critical industries would undermine investment, innovation and the many small businesses that keep the U.S. economy competitive and dynamic. It is a step backward for policy efforts that are working to restore strong U.S. economic competitiveness and growth.

Innovative small businesses are at the heart of America’s medical technology (medtech) industry. They make up more than 80% of this critical sector and have played a key role in helping the U.S. dominate the global medtech market. In fact, in 2024 alone, medical technology and device exports totaled $80 billion.

However, tariffs on medtech would make it harder for this industry to remain an economic powerhouse. Unlike larger corporations, small businesses would find it harder to absorb the increased costs imposed by reciprocal tariffs. In fact, cutbacks in research and development have already occurred due to medtech not being spared from reciprocal tariffs earlier this year.

Moreover, American healthcare would suffer. Hospitals and healthcare providers would face higher costs for the medical supplies needed to save lives. The impacts would be widespread and force many of the more than 700 rural hospitals to make difficult choices. For some, that choice could be closure.

SBE Council has been highly supportive of the Administration’s focus on strengthening America’s economy, innovative capacity and manufacturing base, but we must protect our most vital industries. On behalf of America’s small businesses, I urge the Department of Commerce to exempt the medtech industry from Section 232 tariffs.

Sincerely,

Karen Kerrigan, President & CEO