With a proverbial eye on its goal, AdvaMed is doing its best to steer the Trump administration away from new import taxes on medical devices and equipment.

In comments to the U.S. Department of Commerce, the organization’s top executive painted the medtech industry as an American success story and an export powerhouse less reliant on imports than previously believed. Manifested through a 31-page document, the formal comments were filed with the Commerce Department in response to the U.S. government’s national security investigation into imports of medical devices, industrial machinery, and robotics.

Launched Sept. 2 under Section 232 of the Trade Expansion Act of 1962, the probe is designed to determine whether higher tariff rates are necessary for various medical products like N95 respirators, syringes, surgical masks (and other PPE), coronary stents, heart valves, hearing aids, robotic and non-robotic prosthetics, blood glucose monitors, orthopedic appliances, electromedical apparatus (e.g., computed tomography scanners, magnetic resonance imaging machines); electrosurgical apparatus; X-ray apparatus/other radiation equipment, and MRI machines.

The investigation—which was not disclosed until Sept. 25—will assess current and projected demand for PPE, medical consumables, and medical devices; and whether domestic production can adequately meet that demand. The Commerce Department also is examining the role of foreign supply chains in meeting U.S. demand for medical devices and equipment, and the concentration of U.S. imports of PPE, devices, and equipment as well as associated risks.

In its comments, AdvaMed outlined the investments made by its 600-plus member companies during President Trump’s second term and reiterated its support of the administration’s America First trade policy. “AdvaMed supports the Administration’s America First trade policy with a focus on reciprocal trade and leveling the playing field and creating export opportunities for U.S. medtech manufacturers,” AdvaMed President/CEO Scott Whitaker wrote. “AdvaMed and our members stand ready to support the Administration in developing strong, common-sense policies that strengthen our allied supply chains, drive U.S. exports, and continue to provide innovative medical devices to patients in America and around the world.”

AdvaMed warned that higher tariffs could force manufacturers to cut jobs and hike prices, while also stifling innovation. “Medical technologies are purchased by hospitals through multi-year contracts, and adjustment to cost spikes in the short-term is difficult,” Whitaker noted in his comments. “Such outcomes could ultimately disrupt patient care, destabilize hospitals’ supply chains, substantially increase costs…and undermine our industry’s health care imperative.”

The organization outlined nearly a dozen recommendations to strengthen U.S. medtech production and exports. They included:

• Reciprocal tariff-free trade with Europe, Japan, and the United Kingdom
• Continue USMCA Qualifying Products Rule for Mexico and Canada
• Expand the USMCA-type Qualifying Rule to Costa Rica and the Dominican Republic
• Continue Duty Drawback
• Phased-in implementation of any tariffs
• Establishing a “Make America Healthy Again (MAHA) pathway to fast-track innovation
• Increased global FDA inspections to a level commensurate with U.S. inspections

“AdvaMed and our members stand ready to support the Administration in developing strong, common-sense policies that strengthen our allied supply chains, drive U.S. exports, and continue to provide innovative medical devices to patients in America and around the world,” Whitaker said in his comments. “Through reciprocal trade arrangements with trusted countries, attention to unfair trade practices in other countries, and possible changes to the U.S. regulatory system, we can build upon the industry’s decades-long legacy as a national asset and secure its role in the engine of American medical innovation for generations to come.”