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Tariff impact on medical equipment, as of September 27, 2026
As of September 27, 2026. Most medical equipment imported into the United States now pays one added duty: a Section 301 tariff of 10% or 12.5%, set by country of origin, in force since July 24, 2026. Chinese goods also carry the older China Section 301 duties, which reach 100% on syringes, needles and rubber medical gloves. The 2025 IEEPA tariffs are gone and being refunded. The 10% Section 122 surcharge that replaced them expired on July 24. A Section 232 investigation of medical equipment has been open since September 2025, and nothing has been proclaimed. That is the biggest open risk.
Tariff rates change often. Every rate here was checked against the Federal Register and the current Harmonized Tariff Schedule (HTSUS Revision 19) on September 27, 2026. This is research, not customs or legal advice. Classify your own products with a licensed customs broker or trade counsel.
The duties on HTS 9018 to 9022
“Medical equipment” here means four HTSUS headings: 9018 (instruments, syringes, needles, catheters), 9019 (therapy and respiratory apparatus), 9021 (orthopedic appliances, implants, hearing aids) and 9022 (X-ray and CT apparatus). Most lines carry an MFN rate of Free, including 9018.31.00 syringes, 9018.39.00 catheters and 9021.10.00 orthopedic appliances (HTSUS). The added duties are close to the whole bill.
| Layer | Legal basis | Rate on medical equipment | Status on 2026-09-27 |
|---|---|---|---|
| Section 301, forced-labor actions | USTR notice, 91 FR 47318 | 10% or 12.5% by origin (table below) | In force since July 24, 2026 |
| China Section 301, 2018 lists | HTSUS chapter 99, heading 9903.88.01 | 25% on listed lines, including 9018.12 (ultrasound) and 9022.14 (X-ray) | In force. Some medical products are excluded until November 9, 2026 (heading 9903.88.69). A four-year review opened in May 2026 with no outcome published |
| China Section 301, 2024 increases | HTSUS chapter 99, headings 9903.91.03, .07 and .08 | Syringes and needles (9018.31, 9018.32) 100%. Rubber medical gloves (4015.12.10) 100% from January 1, 2026. Textile face masks and respirators 50% from January 1, 2026 | In force |
| IEEPA tariffs (2025) | Held unlawful in Learning Resources, Inc. v. Trump, February 20, 2026; ended by Executive Order 14389 | None | Ended. CBP is paying court-ordered refunds (91 FR 42207) |
| Section 122 surcharge | Proclamation 11012 | 10%, February 24 to July 24, 2026 | Expired. The HTSUS notes it ended at the close of July 23, 2026. Congress has not extended it |
| Section 232, medical equipment | BIS notice, 90 FR 46383 | None yet | Open since September 2, 2025. No proclamation as of September 27, 2026 |
For China the layers stack. Note 52(a) says goods under the new Section 301 duty “shall also be subject to any additional duty provided for in this subchapter,” which covers the older China 301 headings. A Chinese syringe pays 100% plus 12.5%. A Chinese ultrasound scanner on List 1 pays 25% plus 12.5%, unless one of the open exclusions covers it. Confirm your own line with your broker.
The July 2026 Section 301 rates by origin
From the USTR notice and HTSUS headings 9903.05.20 to 9903.05.84.
| Origin | Section 301 rate | For medical equipment |
|---|---|---|
| European Union (Ireland, Germany, Netherlands, Denmark and others) | 10% net of MFN | With a Free MFN rate, you pay 10% |
| Japan, South Korea, Switzerland | 12.5% net of MFN | With a Free MFN rate, you pay 12.5% |
| Taiwan | 10% net of MFN | |
| Mexico, Canada | 10% | Zero if the goods enter duty-free under USMCA (note 52(g) and (h)) |
| United Kingdom | 10% | Zero on the chapter 90 lines listed in note 52(j)(1). The list covers most of 9019 and 9022 and parts of 9018 and 9021. It does not include syringes, needles and catheters (9018.31 to 9018.39) or orthopedic appliances (9021.10) |
| Malaysia, India, Indonesia | 10% | |
| China, Costa Rica, Dominican Republic, Singapore, Israel, Thailand, Vietnam | 12.5% | China’s older 301 duties still apply on top |
The action also exempts goods under Section 232 tariffs and most entries properly made under HTSUS chapter 98 (note 52(a)). Its general exemption list in note 52(b) has no lines from headings 9018, 9019, 9021 or 9022.
Where the import exposure sits
In 2025 the US imported $74.5 billion of goods under headings 9018, 9019, 9021 and 9022, by country of origin. The source is UN Comtrade’s copy of US-reported imports, FOB value (query for 9018; change cmdCode for the others). The Census API needs a key, so Census was not queried directly. The rate column applies the July 2026 schedule to a line with a Free MFN rate.
| Origin | 2025 imports, $ billion | Share | Section 301 rate from July 24, 2026 |
|---|---|---|---|
| Mexico | 15.9 | 21.4% | 10%, or 0% if USMCA-qualifying |
| Ireland | 9.2 | 12.3% | 10% (EU) |
| Germany | 7.6 | 10.2% | 10% (EU) |
| Costa Rica | 6.9 | 9.3% | 12.5% |
| China | 5.0 | 6.8% | 12.5%, plus China 301 duties |
| Singapore | 3.5 | 4.8% | 12.5% |
| Switzerland | 3.2 | 4.3% | 12.5% |
| Japan | 2.6 | 3.5% | 12.5% |
| Denmark | 1.9 | 2.6% | 10% (EU) |
| Malaysia | 1.9 | 2.5% | 10% |
The mix is very different by heading:
- 9018 (instruments, syringes, catheters, $44.1 billion): Mexico 29.3%, Costa Rica 12.6%, Germany 10.4%, Ireland 7.9%, China 5.2%.
- 9021 (implants, orthopedics, hearing aids, $19.3 billion): Ireland 29.2%, Switzerland 10.9%, Denmark 9.0%, Mexico 7.5%.
- 9019 (respiratory and therapy apparatus, $6.5 billion): Singapore 27.3%, China 25.0%, Mexico 16.9%.
- 9022 (X-ray and CT, $4.7 billion): Germany 33.9%, Netherlands 11.0%, Mexico 10.1%.
- 4015.12 (medical and surgical gloves, $1.9 billion): Malaysia 64.5%, Thailand 19.0%, China 1.6%.
Flows are moving in 2026. From January to July, imports under the four headings fell 7.0% from the same months of 2025, from $44.6 billion to $41.5 billion. Imports from China fell 14.6%, from Mexico 8.7% and from Switzerland 16.8%. Imports from Ireland rose 5.7%. Implants and orthopedics from Costa Rica rose 16.2% (July 2026 query). The 2026 monthly figures are preliminary and will be revised. August 2026 is not yet published. Tariffs are one cause among several, and these numbers do not separate them.
What device makers told investors
Each quote is from the company’s filing on SEC EDGAR, matched word for word against the filed text. Refunds of 2025 IEEPA duties flatter mid-2026 results while the replacement duties keep costing money.
| Company | Filing | What it says |
|---|---|---|
| GE HealthCare | 10-Q, June 30, 2026 | “Tariffs negatively impacted our Operating income by $68 million and $156 million for the three and six months ended June 30, 2026, respectively.” It also “recognized pre-tax benefits from tariff refunds of $106 million related to tariffs incurred in 2025.” |
| Medtronic | 10-K, fiscal year to April 24, 2026 | “Based on current rates as of June 3, 2026, we estimate the pre-tax net tariff impact to be $250 million in fiscal year 2027, excluding any considerations of government refunds.” Fiscal 2026 cost of sales included “$185 million of increased tariffs and duties on imported goods.” |
| Intuitive Surgical | 10-Q, June 30, 2026 | “tariffs and other trade measures recognized in total cost of revenue were $20.8 million and $48.8 million” (three and six months), against “$35.9 million of refunds related to IEEPA tariffs paid in prior periods.” |
| Cardinal Health | 10-K, fiscal year to June 30, 2026 | “we have paid approximately $200 million in IEEPA tariffs.” It will “return to customers the portion of those refunds that reflect the estimated increased prices paid related to IEEPA tariffs.” |
| Teleflex | 10-Q, June 30, 2026 | Second-quarter gross margin “decreased 190 basis points,” “primarily due to the adverse impact from tariffs enacted in 2025” and other factors. |
| Baxter | 10-Q, June 30, 2026 | It “recorded tariff refunds of approximately $75 million to costs of goods sold” and expects results “will continue to be adversely impacted by Section 122 duties and recently announced Section 301 tariffs.” |
| Zimmer Biomet | 10-Q, June 30, 2026 | “Prior to the Supreme Court ruling, we had paid IEEPA tariffs of approximately $77 million.” |
| Stryker | 10-Q, June 30, 2026 | The second-quarter gross margin bridge shows “Reversal of 2025 tariffs” at 260 bps. That is a refund, not a current cost. |
These numbers do not compare directly. GE HealthCare’s costs are gross of refunds. Medtronic’s $250 million is a forecast that excludes refunds. Stryker’s and Zimmer Biomet’s figures are refund effects.
Mitigation with evidence behind it
| Option | Evidence | What to check on your lines |
|---|---|---|
| Recover 2025 IEEPA duties | Most filers above booked refunds in the second quarter of 2026. The Court of International Trade ordered refunds in Atmus Filtration, Inc. v. United States on March 4, 2026, and CBP runs a refund worksheet (91 FR 42207) | Which of your entries paid IEEPA duties, and whether your customers are owed a share. Cardinal Health says it will pass part back |
| Qualify goods under USMCA | Intuitive Surgical makes most instruments in Mexicali and says “Most of these products qualify as originating under the USMCA and, therefore, have not been subject to U.S. import tariffs to date.” Teleflex is “increasing the proportion of USMCA-compliant products in our portfolio” (10-K for 2025) | Canadian and Mexican goods entered duty-free under USMCA are exempt from the July 2026 duty |
| Claim exemptions and exclusions | BD: “sourcing optimization and tariff exemptions for qualifying products are key aspects of our mitigation strategy” (10-Q). Edwards will pursue “potential exemptions and exclusions” (10-Q) | Chapter 98 entries are exempt from the new 301 duty. One example is 9817.00.96, for articles specially designed or adapted for people with disabilities; it has conditions. China 301 exclusions under heading 9903.88.69, which cover some ECG electrodes, ultrasound scanners, pulse oximeters and X-ray tube housings, run through November 9, 2026 |
| Re-source by origin | Dentsply Sirona is “evaluating alternative sourcing options to minimize products sourced from high tariff rate countries” (10-Q). Teleflex cites “supply chain optimization strategies and adjustments to chain-of-custody protocols” | The gap is now small: 10% for EU, non-USMCA Mexican or Malaysian goods, 12.5% for Costa Rican, Singaporean or Chinese goods. For Chinese syringes, needles and gloves it is still wide |
| Raise prices | Cardinal Health: “increasing prices on impacted products to customers; however, these measures have not fully offset the adverse impact.” Dentsply Sirona cites “competitive pricing strategies to offset tariffs” | Your contract terms. Baxter says it is “limited in our ability to pass these cost increases on to our customers in a timely manner or at all due to the longer term nature of our customer contracts” |
None of these filings mentions duty drawback, foreign-trade zones or inventory pre-builds, so this page makes no claim about how common they are. Zones are still an option, with a limit: goods admitted after the July action took effect must enter in “privileged foreign status.”
What is still open
- Section 232 on medical equipment. Commerce opened it on September 2, 2025. The statute gives Commerce 270 days to report, and no proclamation had appeared in the Federal Register by September 27, 2026. If one comes, it would replace the Section 301 duty on the same goods, because the July action exempts Section 232 articles.
- More Section 301 cases. USTR opened structural excess capacity investigations in March 2026 into 16 economies, including the EU, China, Mexico, Japan, Singapore and Switzerland. No action has been published.
- The China four-year review. It could keep, change or end the 2018 duties. No outcome has been published.
- China 301 exclusions. The current list ends November 9, 2026 unless USTR extends it.
- Refund timing. Intuitive Surgical: “The amount and timing of any additional refunds remain uncertain and are subject to CBP review and the outcome of ongoing legal proceedings.”
Build the same brief for your lines
- List what you import by 10-digit HTS number and country of origin. Use your entry summaries (CBP Form 7501) or your broker’s ACE reports, not the product catalog.
- Look up each line in the HTSUS for the MFN rate. Then check chapter 99 for every heading that names your code or origin: 9903.88 (China 2018 lists and exclusions), 9903.91 (China 2024 increases) and 9903.05 (the July 2026 actions).
- Multiply customs value by the summed rates for each line and origin, and total it over twelve months of entries.
- Mark each line as fixable or not: USMCA qualification, chapter 98 eligibility, open exclusions, and a second source in a lower-rate origin.
- Read the tariff paragraphs in the latest 10-Q of the three public companies closest to your mix. EDGAR full-text search finds them.
- Date everything. Write the open items (Section 232, pending Section 301 cases, the exclusion expiry) as scenarios with a rate and a date.
Where Hyperresearch fits
Steps 2, 5 and 6 are the slow part: the chapter 99 notes, the Federal Register notices and a dozen filings, with every figure tied to its source. A Hyperresearch run can do that reading for one product line or a whole category and returns a cited report; every sampled citation is checked against the source it cites. It does not see your entry data, classify your products or give customs or legal advice. See pricing.
For sizing a market from trade tables, see how to calculate market size.
By Jordan Gibbs · Updated 2026-09-27