GOED has submitted a letter to the Secretary of the United States Department of Commerce addressing the issue of tariff exemptions for EPA and DHA imports. The letter was written in response to a request for public comments for a Section 232 National Security Investigation of Imports of Pharmaceuticals and Pharmaceutical Ingredients.
As background, the dietary ingredients included in the Annex II exemption list, announced on April 2, have been determined to be connected to the pharmaceutical industry. When the full scope of international tariffs was announced, these items were included in the categories exempt from tariffs. The Trump Administration has since announced that it is considering assessing tariffs on foreign-based pharmaceuticals and ingredients if it determines that a reliance on a higher percent of foreign active pharmaceutical ingredients (APIs) and pharmaceutical inputs could be a national security risk, and as a result, issued a request for public comments on the topic.
Because more than 40 of the exempted ingredients in Annex II were also dietary ingredients used in the production of dietary supplements, GOED took this opportunity to make the argument that EPA and DHA omega-3 oils (the codes for two of which were included in the Annex) were crucial to maintaining the health of Americans, and an exemption for ALL omega-3 oils was warranted. We shared with the Department of Commerce the tariff codes provided by our members and requested an exemption for all based on the fact that, “These fatty acids are crucial to the viability of virtually every cell in the human body and are of vital importance across the lifespan, beginning with prenatal health…and continuing through to adulthood...” Similar arguments were submitted by US-based trade associations, GOED partner United Natural Products Alliance, and the Natural Products Association.
GOED will keep members informed regarding a response to our letter or any further developments.
GOED last reported on this issue in a 17 April 2025 Breaking News alert.
