IEEPA Tariff Refunds for Pharmaceutical and Medical Supply Importers

How IEEPA tariffs hit pharmaceutical and medical products

• Pharmaceuticals. Annex II of the April 2025 reciprocal tariff order exempted pharmaceuticals from the reciprocal tariff. An order effective September 8, 2025 adjusted Annex II, including for pharmaceutical products under Section 232 investigation.
• Medical devices and supplies. Medical devices, consumables such as syringes and IV bags, and protective equipment were not in Annex II, so they paid the reciprocal tariff at the origin country's rate. That duty may be refundable.
• China. China-origin goods also paid the separate IEEPA duty tied to synthetic opioids.

What is not refundable

• Section 301 duties on Chinese medical products, which were raised in 2024 and 2025 for items such as syringes and needles, medical gloves, and face masks.
• Section 232 duties on pharmaceuticals under a proclamation signed in April 2026.

Commerce opened a Section 232 investigation into protective equipment, medical consumables, and medical devices in September 2025. Duties that result from it would also be outside the IEEPA refund.

Records to have ready

• HTS codes by product, to see which lines were in Annex II
• ES-003 report with IEEPA lines
• CAPE results and refunds received

How we can help

We explain the general options for your situation in plain English, show you which ACE reports to pull, and email you a list of licensed customs brokers and attorneys who handle it. The review is free for importers. We do not file with CBP or give legal advice.

General information, not legal or customs advice. Facts last reviewed September 24, 2026. Confirm dates and options for your entries with a licensed professional.