U.S. Department of Commerce Launches National Security Investigation—This Could Impact Nearly Every Segment Of The Medical Supply Chain

Published in Government Relations on September 29, 2025

The U.S. Department of Commerce announced Friday, Sept. 26, the initiation of a national security investigation into the importation of personal protective equipment (PPE), medical consumables, and medical equipment, including devices. The investigation, launched on Sept. 2, 2025, is being conducted under Section 232 of the Trade Expansion Act of 1962.

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. 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.

Potential Impacts

Sections 232 of the Trade Expansion Act of 1962 empowers the U.S. government to investigate the effects of certain imports on national security. Previously, it was used to investigate the steel industry, resulting in higher tariffs.

The DMEPOS industry now faces a similar investigation. The Bureau of Industry and Security (BIS), through its Office of Strategic Industries and Economic Security, is leading the inquiry to assess whether reliance on foreign sources for these critical healthcare items poses a threat to U.S. national security.

Much like the steel industry, it is possible—perhaps even likely—that the DMEPOS industry will see higher tariffs as a result of this investigation. Many across the healthcare industry, including VGM Group are sounding the alarm: Increased tariffs could increase costs for hospitals and patients, reduce access to critical equipment, and negatively impact patient quality of care.

Scope

The investigation examines a wide range of healthcare-related imports including, but not limited to:

Personal Protective Equipment (PPE): Surgical masks, N95 respirators, gloves, gowns, and related components.
Medical Consumables: Syringes, IV bags, catheters, anesthesia equipment, diagnostic reagents, and other single-use items.
Medical Equipment and Devices: Wheelchairs, CGMs, prosthetics, hospital beds, ventilators, MRI machines, pacemakers, insulin pumps, and other durable healthcare technologies.

Pharmaceuticals are excluded from this investigation and are being reviewed separately under a different Section 232 inquiry.

Public Comments Are Open

The public comment period is now open until Oct. 17. The Department is seeking public input on a range of issues including but not limited to:

Domestic production capacity and demand.
Foreign supply chain dependencies and risks.
Impact of foreign subsidies and unfair trade practices.
Potential national security threats from foreign control or export restrictions.
Feasibility of increasing U.S. manufacturing to reduce import reliance.

To review the full notice, go to the Federal rulemaking portal: https://www.federalregister.gov/public-inspection/2025-18729/section-232-national-security-investigation-of-imports-of-personal-protective-equipment-medical

Comment Before Oct. 17

This investigation has consequences for the entire DMEPOS industry, especially our manufacturers and distributors. It is critical that we make our voice as an industry heard by commenting ahead of the Oct. 17 deadline.

To comment:

Click the following link: https://www.regulations.gov/search?filter=2025-18729.
When you are ready to comment, click the “Comment” button to the right of the document.
Type a comment in the open field, and upload up to 20 supporting documents.
- *Please note: Comments submitted in the open field are public.
The regulations.gov ID for this notice is BIS-2025-0258. Please refer to XRIN 0694-XC134 in all comments.

VGM will monitor and keep you updated on any developments. And as always, we will continue to advocate for what’s best for the entire industry.