U.S. Launches 232 Investigation on Imported Robots, Medical Equipment

The United States Department of Commerce has initiated an investigation under Section 232 of the Trade Expansion Act, focusing on imported robots, industrial machinery, and medical equipment. The investigation began on September 2, 2020. According to this law, the U.S. President has the authority to impose tariffs on key commodities deemed critical to national security. The Department of Commerce is required to submit policy recommendations within 270 days.

This latest investigation expands the range of industries in the U.S. that may face tariffs. Experts interviewed by a financial news outlet have stated that the Trump administration is using increased import costs to encourage domestic manufacturing of key industries. A long-time logistics industry professional in the U.S. noted that if the investigation into robots and industrial equipment proceeds, it will undoubtedly increase manufacturing costs in the U.S. The professional also mentioned that the U.S. lacks the immediate capability to produce these equipment domestically, making the goal of reviving U.S. manufacturing a mix of objective realities and increasingly severe nationalist sentiments, presenting a harsh reality for foreign companies investing in the U.S.

To date, the U.S. has initiated 232 investigations into 11 categories, including steel and aluminum and their derivatives, automobiles, copper, semiconductors, pharmaceutical products, key minerals and their derivatives, trucks, lumber, commercial aircraft and engines and their components, unmanned aerial vehicle systems and their components, and polysilicon and its derivatives. The Trump administration has already invoked this law to impose 232 tariffs on automobiles, copper, steel, and aluminum products.

The investigation into imported robots and industrial machinery involves a broad range of equipment, including but not limited to programmable computer-controlled mechanical systems, CNC machining centers, lathes and milling machines, grinding and deburring equipment, industrial presses, automatic tool changers, fixtures, and machine tools used for cutting, welding, and material handling. Specialized metal processing, forming, or cutting equipment, such as high-pressure sterilizers and industrial ovens, metal finishing and processing equipment, electrical discharge machining, laser and water jet cutting tools and machinery, are also included. However, this investigation does not cover unmanned aerial vehicle systems, which are addressed by another Section 232 investigation.

The Department of Commerce has requested that interested parties submit written comments, data, analyses, or information related to this investigation to the Office of Strategic Industries and Economic Security within 21 days of the Federal Register publication. Key areas of interest include the current, expected, and optimal demand for robots and industrial machinery and their components within the U.S., the extent to which domestic production can meet this demand, the role of foreign supply chains (especially major exporting countries) in meeting U.S. demand for these products, and the risks associated with high concentration of imports from a few suppliers or foreign countries.

The Department of Commerce also seeks to understand the feasibility of increasing domestic production capacity to reduce import dependence, the impact of current trade policies on domestic production of robots and industrial machinery and their components, and whether additional measures such as tariffs or quotas are necessary to protect national security. Additionally, the impact of the use or non-use of robots and industrial machinery on U.S. manufacturing employment is of interest.

The second investigation focuses on the U.S. government's concern over the country's reliance on foreign supplies of various medical consumables, including syringes, sutures, catheters, and gauze. This investigation covers imported personal protective equipment (PPE), medical consumables, and medical devices (including equipment). PPE includes items used in healthcare settings, such as surgical masks, N95 respirators, gloves, protective clothing, and related medical components. Medical consumables are single-use or short-term items used for patient diagnosis, treatment, and disease prevention, including medical/surgical instruments (such as syringes, needles, infusion pumps, forceps, scalpels), medical/surgical consumables (such as infusion bags, catheters, endotracheal tubes, anesthesia equipment, gauze/bandages, sutures, diagnostic and laboratory reagents), and related medical components. Medical equipment refers to durable equipment, tools, and instruments used in healthcare to support patient care, such as hospital beds, wheelchairs, crutches, and hospital beds. Medical devices are any instruments, apparatus, or machines used for disease diagnosis, monitoring, or treatment, including but not limited to pacemakers, insulin pumps, coronary stents, heart valves, hearing aids, robotic and non-robotic prosthetics, blood glucose monitors, orthopedic devices, electromedical equipment (such as CT scanners, MRI machines), electrosurgical equipment, X-ray equipment/other radiation equipment, ventilators (such as ventilators, respirators, oxygen supply equipment), and MRI machines.

This new medical equipment investigation does not cover prescription drugs, biologics, and other pharmaceuticals, which are already within the scope of another independent investigation by the Department of Commerce. The Department of Commerce is seeking information on the current and projected demand for PPE, medical consumables, and medical devices (including equipment) in the U.S., the extent to which domestic production can meet this demand, and the feasibility of increasing domestic production capacity.

Regarding the effectiveness of using tariffs and other policy measures to bring manufacturing back to the U.S., a China Center expert at the Brookings Institution expressed skepticism. The expert noted that it is unlikely that anyone in the U.S. would be willing to take on simple manufacturing jobs, as these positions are seen as having limited prospects for advancement. Even if such jobs were available, local Americans might not be interested in taking them.