Lexology September 26, 2025
Hogan Lovells

We are closely following the recent Section 232 investigation initiated by the U.S. Department of Commerce’s Bureau of Industry and Security. A Section 232 tariff investigation is a formal process conducted by the U.S. government to determine whether imports of certain products threaten national security or harm domestic industries, and whether trade measures like tariffs (import taxes) or quotas (import limits) should be imposed. This investigation, initiated on September 2, 2025, could have significant implications for the medical device industry. It is therefore critical that manufacturers and importers understand both the legal process and the potential business impacts.

The legal foundation

Section 232 of the Trade Expansion Act of 1962 gives the President broad authority to adjust imports if they...

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