VGM Submits Comments Regarding the Section 232 National Security Investigation On Medical Imports

Published in Government Relations on October 09, 2025

VGM has submitted formal comments to the U.S. Department of Commerce in response to its Section 232 National Security Investigation into the importation of personal protective equipment (PPE), medical consumables, and medical equipment and devices. 

While we recognize the importance of strengthening domestic supply chains and safeguarding national security, VGM emphasized that any resulting trade restrictions must be carefully considered to avoid unintended harm to the durable medical equipment (DME) industry and the patients it serves. 

The submitted comments outlined below include several significant challenges that the DME industry could face if the investigation leads to increased trade restrictions: 

1. Tariffs and Cost Increases. If new tariffs are imposed on imported medical equipment and components, manufacturers will experience immediate cost hikes. Many essential parts, used in products like wheelchairs, ventilators, and hospital beds, are sourced internationally due to cost and availability. These tariffs could raise production costs, reduce affordability, and limit access for patients and providers. 
2. Supply Chain Disruption. The DME industry depends on a global supply chain to deliver timely and diverse products. Trade restrictions or tariffs could disrupt this system, causing delays, shortages, and uncertainty, especially critical items like prosthetics, insulin pumps, and glucose monitors that are vital to patient health. 
3. Limited Domestic Manufacturing Capacity. While boosting domestic production is a worthy goal, current U.S. infrastructure cannot quickly scale to meet demand across all DME categories. Moving away from foreign suppliers without viable domestic alternatives could lead to service gaps. Any shift must consider realistic timelines, investment needs, and workforce readiness. 
4. Impact on Patient Care and Providers. Higher costs and reduced access to DME products will directly affect patient outcomes. Providers may have to cut services, delay treatments, or pass costs onto patients, undermining healthcare resilience and compromising care quality. 
5. Risk of Unintended Consequences. Efforts to reduce foreign dependency must be carefully tailored. Broad, one-size-fits-all policies could unintentionally harm U.S. manufacturers who rely on global inputs, stifle innovation, and reduce competitiveness. 

VGM urges the Department of Commerce to take a balanced, collaborative approach that protects national interests without compromising patient care or destabilizing the DME industry. We encourage policymakers to engage with stakeholders across the healthcare continuum to ensure that any future policies support both supply chain resilience and the continued delivery of high-quality, affordable medical equipment to those who need it most.

To submit comments and review the full Section 232 National Security Investigation notice, go to the Federal Rulemaking Portal.