Medical Technology: Section 232 – early expectations

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Medical Technology: Section 232 – early expectations

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Medical Technology

Section 232 – early expectations

Industry Overview

Section 232 announcement to come in the next months 29 June 2026

We have had many investor questions on the upcoming section 232 tariffs. The Equity

Department of Commerce launched an investigation into medical devices & United States

consumables on Sept 2, 2025. The deadline for the final announcement/ presidential Medical Technology

determination is Aug 28, 2026. The actual implementation will then take place within 15 Travis Steed

days after the announcement. We think the med device 232 could potentially come Research Analyst

earlier than the official deadline - current broad Section 122 tariffs expire July 24. The BofAS+1 404 607 3251

industry-specific 232’s are seen as more permanent replacement of IEEPA tariffs, while travis.steed@bofa.com

the 122 serves as the bridge. It’s possible that the Section 232 can be coordinated to be Stephanie Elghazi

Research Analyst

announced when the Section 122 tariffs expire in July. BofAS

+1 646 855 4568

Nairobi protocol most likely stays, USMCA could remain stephanie.elghazi@bofa.com

Gracia Mahoney

From our conversations with companies and industry consultants, we think the Nairobi Research Analyst

protocol most likely holds under section 232, so hip/knee replacements and diabetes BofAS

+1 646 855 1136

devices would stay exempt from tariffs. On USMCA, the Autos section 232 exempted US gracia.mahoney@bofa.com

content in automobiles (tariffs only on non-US content) and exempted USMCA qualifying Enjia Cao

auto parts for now. We think the Autos Section 232 sets a precedent for some USMCA Research Analyst BofAS

carve-out under section 232. +1 646 743 9861

enjia.cao@bofa.com