Pharma and Semiconductor Investigations: Comment Period Opens

On April 14, 2025, the Bureau of Industry and Security (BIS) announced the opening of a public comment period related to the new Section 232 investigations on imports of pharmaceuticals and pharmaceutical ingredients, semiconductors and semiconductor manufacturing equipment. BIS is interested in comments, data, analyses, or information directed at the criteria listed in § 705.4 of the regulations as they affect national security. Comments are due by May 7, 2025, 21 days after the date of publication in the Federal Register (April 16, 2025).

Semiconductor Investigation Product Scope

The scope of the investigation includes, among other things, semiconductor substrates and bare wafers, legacy chips, leading-edge chips, microelectronics, and Semiconductor Manufacturing Equipment (SME) components.

• Semiconductors
• Semiconductor Manufacturing Equipment
• Derivative Products include downstream products that contain semiconductors, such as those that make up the electronic supply chain.

Pharmaceutical Investigation Product Scope

The scope includes both finished generic and non-generic drug products, medical countermeasures, critical inputs such as active pharmaceutical ingredients and key starting materials, and derivative products of those items.

• Pharmaceuticals
• Pharmaceutical ingredients
• Derivative products

For more information on submitting a public comment, please refer to the Federal Register notices:

Federal Register :: Public Inspection: National Security Investigation of Imports of Pharmaceuticals and Pharmaceutical Ingredients

Federal Register :: Public Inspection: National Security Investigation of Imports of Semiconductors and Semiconductor Manufacturing Equipment

Have Questions? Contact your local NNR Representative.

We will continue to monitor this tariff action and provide updates as they become available.