US launches investigation into pharmaceuticals and semiconductors

• The Department of Commerce's Bureau of Industry and Security (BIS) has initiated Section 232 investigations into imports of pharmaceuticals and semiconductors, as of 1 April 2025.
• The Secretary of Commerce is seeking public comments pertinent to the investigations.
• The comment period is only 21days long, ending on 7 May 2025.

In Federal Register Notices (FRNs) that are scheduled for publication on 16 April 2025, the United States (US) Secretary of Commerce seeks public comments related to investigations into imports of pharmaceuticals and pharmaceutical ingredients and semiconductors and semiconductor manufacturing equipment. The FRNs clarify that the Department of Commerce's Bureau of Industry and Security (BIS) initiated both investigations to determine the effects that the importation of these goods has on the national security. The investigations were initiated under Section 232 of the Trade Expansion Act of 1962 (Section 232) on 1 April 2025.

These investigations follow Section 232 investigations initiated earlier this year (2025) into imports of timber, lumber and their derivative products, and copper, scrap copper and copper derivatives. (See EY Global Tax Alert, US initiates investigation into imports of timber, lumber and their derivative products, dated 4 March 2025.)

Comments for both investigations must be submitted, no later than 21 days after the date of each FRN's publication, on the federal rulemaking portal at: www.regulations.gov.

Actions for businesses to consider

The following actions could help businesses prepare for and adapt to these regulatory changes:

• Provide comments regarding the investigations on the federal rulemaking portal.
• Review import data to understand the potential impact.
• Prepare contingency plans to address potential disruptions to pharmaceuticals and semiconductors due to potential changes in trade policies and market conditions.
• Monitor any further updates or changes to the regulations and adjust processes as needed.
• Keep up with the latest news and developments in trade policies and stay adaptable to quickly respond to changes in trade regulations and tariff rates.