Proposed Section 232 Investigation on Med Device Imports Could Undermine U.S., MI's Medtech Strength

The U.S. Department of Commerce’s decision to launch a Section 232 investigation into imports of medical devices and related equipment has raised significant concern across the nation’s medical technology (medtech) sector. While the stated intent—to assess potential threats to national security—is understandable, the proposed trade restrictions risk disrupting a high-performing, innovation-driven industry that is already a cornerstone of American economic and health security. 

U.S. Medtech: A Proven National Asset 

The U.S. medtech industry stands as a uniquely American success story in advanced manufacturing and innovation. According to BMI (a Fitch Solutions company), U.S.-made medical technologies account for 70 percent of the domestic market, reflecting a deep and resilient manufacturing base. Since 2017, medtech manufacturing output has grown steadily, with job creation three times the national manufacturing average. 

With approximately $80 billion in exports in 2024, the industry contributes more to U.S. trade than automobiles or semiconductors. Medtech supports more than three million jobs nationwide—across R&D, production, and supply chains—offering wages that exceed the average manufacturing salary. These metrics affirm that medtech is not just an economic powerhouse but also a vital component of national security infrastructure. 

Imports Complement, Not Compete 

Contrary to claims that foreign imports threaten domestic capacity, the facts reveal a highly integrated and complementary global supply chain. Only 30 percent of U.S. medtech products are imported, and the majority of these come from trusted allies in Europe and North America. Imports fill critical gaps, ensuring that American healthcare providers have timely access to over two million regulated technologies that no single nation could fully produce alone. 

The industry’s balanced trade relationships—including surpluses with China, Japan, India, Brazil, and Canada—highlight that U.S. medtech is far from dependent on non-allied sources. Imports from China, for instance, represent less than three percent of total market share. 

Tariffs Would Raise Costs and Threaten Access 

Imposing tariffs on medical devices would immediately raise costs for hospitals, clinics, and patients—contradicting the Administration’s broader goal of expanding affordable healthcare access. Many rural hospitals, already operating on razor-thin margins, would face even greater financial strain. 

Over 700 rural hospitals nationwide are at risk of closure, with 300 in immediate jeopardy. Tariffs would further inflate the cost of essential medical equipment, from diagnostic tools to life-saving devices, forcing cutbacks or closures that could leave millions of rural Americans without timely care. The resulting delays and reductions in access could lead to worsened health outcomes and preventable deaths. 

Threats to Innovation and R&D Investment 

The medtech industry reinvests roughly 6–8 percent of revenues—more than $20 billion annually—into research and development. These investments drive constant innovation, with new technologies and product iterations emerging every one to two years. Trade disruptions and reciprocal tariffs already have dampened R&D spending in some segments, threatening to erode America’s leadership in health technology innovation. 

Furthermore, medtech manufacturing cannot be easily or quickly relocated. The FDA’s stringent requirements mean any change in production site demands a lengthy revalidation process to ensure safety and efficacy—potentially taking years. Tariffs, therefore, would not spur domestic reshoring but instead disrupt access to critical devices during the transition. 

Implications for Michigan’s Medtech Industry 

Michigan is home to a robust and growing medtech ecosystem, comprising hundreds of manufacturers, innovators, and suppliers that provide thousands of high-value jobs statewide. Companies across the state—from Grand Rapids to Ann Arbor—produce life-saving diagnostics, imaging systems, surgical instruments, and advanced materials used globally. 

These firms rely on stable trade conditions to sustain R&D, manage complex supply chains, and maintain competitiveness in international markets. Tariff-related disruptions could reverberate through Michigan’s economy, slowing investment, hampering exports, and threatening local employment. 

MichBio’s Position and Public Comment to the Department of Commerce 

On October 16, 2025, MichBio—Michigan’s biosciences industry association—submitted formal comments to the Department of Commerce, emphasizing that tariffs on medical devices would harm, not help, U.S. national and economic security. 

“The dominance of U.S. medtech is an asset to our national security and economic resilience,” wrote Stephen Rapundalo, PhD, MichBio President and CEO. “The industry’s proven ability to respond rapidly to crises—such as during the COVID-19 pandemic—demonstrates that our domestic capacity and international partnerships already ensure a secure and reliable supply of critical medical devices. We urge the Department to avoid actions that could disrupt this uniquely American success story.” 

Strengthening, Not Penalizing, a National Strength 

Rather than imposing tariffs that would burden healthcare providers and slow innovation, federal policy should focus on bolstering domestic manufacturing capacity through targeted investment, workforce development, and public-private partnerships. 

As AdvaMed notes, the medtech industry has consistently demonstrated its ability to scale production during crises, as seen during the pandemic when U.S. manufacturers rapidly became self-sufficient in producing COVID-19 tests and protective equipment. Policies that reinforce this resilience—rather than undermine it—will best serve American patients, workers, and national interests. 

Conclusion 

The Section 232 investigation presents a pivotal moment for U.S. policymakers. A tariff-based approach risks unraveling a globally admired, innovation-led sector that contributes to both the nation’s health and its economy. The U.S. medtech industry exemplifies how strategic trade relationships, domestic investment, and cutting-edge research together advance national security and patient care. 

Michigan’s medtech community—and indeed, the entire U.S. industry—stands ready to work with the Administration to strengthen resilience without sacrificing affordability, access, or innovation.