Gov’t launches investigation into medical equipment import vulnerabilities 

WASHINGTON – The U.S. Department of Commerce has initiated an investigation into the potential national security risks associated with importing personal protective equipment (PPE), medical consumables and medical equipment, according to a Sept. 29 notice of request for public comments. 

“While this may sound like simple information gathering, the outcomes of this investigation have serious implications for our industry, with potential impact to nearly every segment of the medical supply chain,” VGM Government Relations stated in an alert. “We, as an industry, need to ensure the department understands how its decisions will impact our industry’s manufacturers, providers, and ultimately, our nation’s patients.”  

The Department of Commerce is particularly interested in comments and information on the following: 

• The current and projected demand for PPE, medical consumables, and medical equipment, including devices, in the United States; 
• The extent to which domestic production of PPE, medical consumables, and medical equipment, including devices, can meet domestic demand; 
• The role of foreign supply chains, particularly of major exporters, in meeting United States demand for PPE, medical consumables, and medical equipment, including devices; 
• 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; 
• 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; 
• 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; 
• 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); 
• The feasibility of increasing domestic capacity for PPE, medical consumables, and medical equipment, including devices, to reduce import reliance; 
• 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; 
• The potential for foreign control or exploitation of supply chains for PPE, medical consumables, and medical equipment, including devices, supply chain; 
• The ability of foreign persons to weaponize the capabilities or attributes of foreign-built PPE, medical consumables, and medical equipment, including devices 

The department defines medical equipment as durable equipment, tools and machines used in health care to support patient care. Examples include but are not limited to wheelchairs, crutches and hospital beds. 

The investigation, launched on Sept. 2, 2025, is being conducted under Section 232 of the Trade Expansion Act of 1962.  This act empowers the U.S. government to investigate the effects of certain imports on national security. Previously, it was used to investigate the steel industry and resulted in higher tariffs. 

The department is accepting public comments until Oct. 17. 

• FMI: https://www.federalregister.gov/documents/2025/09/26/2025-18729/notice-of-request-for-public-comments-on-section-232-national-security-investigation-of-imports-of.