In a meeting with the United States Trade Representative, AHPA received confirmation that commodities included in Annex II of the Executive Order on TARIFFS that were not already subject to Section 232 duties were selected to be subject to investigation and the potential imposition of import controls.
AHPA’s category of concern within Annex II’s long list of Commodities is DIETARY INGREDIENTS. This category includes vitamins, amino acids, and other substances used in the creation of products manufactured and sold by AHPA members such as dietary supplements and personal care products. An imposition of import controls on the Dietary Ingredients listed in Annex II would adversely impact AHPA members.

On May 2, 2025, AHPA responded to a request for public comments on Section 232: National Security Investigation of Imports of Pharmaceuticals and Pharmaceutical Ingredients. Read AHPA’s FULL Response >>
Points of discussion in AHPA’s response include:
- Domestic capacity for Annex II dietary ingredients production is limited.
- Import controls on Annex II dietary ingredients will do harm to national security.
- Domestic production of Annex II dietary ingredients is better driven by positive trade measures.


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