On December 1, 2025, the United States and United Kingdom announced an agreement in principal on pharmaceuticals, pharmaceutical ingredients, and medical technology. Under the agreement, the U.S. will:
- Exempt U.K.-origin pharmaceuticals, pharmaceutical ingredients, and medical technology from Section 232 tariffs;
- Refrain from targeting U.K. pharmaceutical pricing practices in any future Section 301 investigation for the duration of President Trump’s term; and
- Work to ensure U.K. citizens have access to the latest pharmaceutical breakthroughs.
While a list of Harmonized Tariff Schedule of the United States (“HTSUS”) classifications that fall under this announcement has not yet been announced, we believe the HTSUS list should be close to, if not identical, to those pharmaceutical, pharmaceutical ingredients, and medical technology currently exempt from all International Emergency Economics Powers Act (“IEEPA”) tariffs due to ongoing Section 232 investigations.
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