Procedures To Apply for Company-Specific Onshoring Agreements To Obtain Tariff Adjustments for Pharmaceuticals and Pharmaceutical Ingredients Under Proclamation 11020

Brief takeaway: The notice sets up an application process by which pharmaceutical manufacturers can negotiate company-specific onshoring agreements with Commerce to obtain a reduced Section 232 duty rate.

What changed: According to the notice, Commerce is announcing procedures for pharmaceutical manufacturers to apply for company-specific agreements to onshore manufacturing of pharmaceutical products and their ingredients. The notice states that companies entering into such agreements are eligible for a reduced Section 232 duty rate on imports of their pharmaceutical products and associated ingredients, and requests that applications be submitted within 30 days of publication in the Federal Register.

Who's affected: The notice names companies that manufacture pharmaceutical products, and cites pharmaceutical products and pharmaceutical ingredients as the covered goods under Proclamation 11020 and Section 232. Specific HTS codes and countries of origin are not specified in the notice.

What to review:
- Review whether your company manufactures pharmaceutical products or ingredients that may fall within the scope described in the notice.
- Confirm the application submission window and required contents with Commerce, since the notice cites a 30-day period from publication.
- Check with your licensed customs broker whether any Section 232 duties currently apply to your pharmaceutical imports.
- Review whether pursuing a company-specific onshoring agreement may be relevant to your sourcing and manufacturing plans.

This is general information, not legal advice and not a compliance determination — confirm specifics with a licensed customs broker or trade counsel.