The Commerce Department’s Bureau of Industry and Security (BIS) in two (2) Federal Register notices said it is soliciting public comments for Section 232 investigations involving pharmaceuticals and semiconductors, which were initiated on April 1st.

Through the Section 232 investigation into pharmaceuticals, the Commerce Department said that it is trying to determine the effects on national security of imports of pharmaceuticals and pharmaceutical ingredients and their derivative products. This includes both finished generic and non-generic drug products, medical countermeasures, critical inputs, such as active pharmaceutical ingredients and key starting materials, and derivative products of those items.

In addition, through the Section 232 investigation into semiconductors, the Commerce Department said that it is trying to determine the effects on national security of imports of semiconductors, semiconductor manufacturing equipment, and their derivative products. This includes, among other things, semiconductor substrates and bare wafers, legacy chips, leading-edge chips, microelectronics, and SME components. Derivative products include downstream products that contain semiconductors, such as those that make up the electronics supply chain.

The comments are due 21 days, or by May 7th, 2025, after the scheduled publication date of April 16th for these two (2) notices in the Federal Register. 

RIM will continue to closely monitor this evolving situation and provide updates as necessary. Please reach out to your RIM representative should you have any further questions.