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.”