Section 232: Drawback Relief for Pharma Tariffs
When the President’s April 2, 2026 proclamation under Section 232 of the Trade Expansion Act of 1962 (19 U.S.C. § 1862) imposed a default 100% ad valorem duty on imports of patented pharmaceuticals and active pharmaceutical ingredients (APIs) listed in Annex I (see our cheat sheet) the industry response was predictable: spreadsheets, scenario models, and a lot of anxious calls to trade counsel. But buried in clause (10) of the proclamation is a single sentence that should be on every drug importer’s whiteboard:
“Drawback shall be available with respect to the duties imposed pursuant to this proclamation.”
SCOTUS Overrules IEEPA Tariffs: What Importers Should Know
Reciprocal tariffs from the Trump administration are now confirmed duty drawback eligible, creating a major opportunity to recover tariffs on imports tied to exports.
Reciprocal Tariffs are Drawback Eligible
Reciprocal tariffs from the Trump administration are now confirmed duty drawback eligible, creating a major opportunity to recover tariffs on imports tied to exports.
Section 301 Tariff Eligibility
Under Section 301, the USTR under the Trump Administration investigated whether China’s policies on tech transfer and IP unfairly burden U.S. commerce.