Mollie Sitkowski Discusses CBP’s Guidance on Section 232 Pharma Tariffs in International Trade Today

Customs and international trade partner Mollie Sitkowski spoke with International Trade Today to discuss the US Customs and Border Protection’s (CBP) guidance on Section 232 tariffs for pharmaceutical products.

According to the article, importers of patented pharmaceutical products subject to Section 232 tariffs were required to begin reporting applicable chapter 99 Harmonized Tariff Schedule codes on July 31, 2026. Sitkowski suggested the codes are intended to help assess the effects of tariffs and to encourage companies to onshore operations and enter into “most favored nation” agreements.

Sitkowski also commented on CBP guidance that broadened the scope of the US origin exemption, raising questions about whether it applies to all pharmaceuticals with US origin active pharmaceutical ingredients, or just those in dosage form. She noted that CBP has the ability to clarify the intent of the proclamation, pointing to similar confusion within the trade community surrounding Section 122 tariffs.

“I think based on that confusion with the Section 122 tariffs, CBP felt like, 'OK, we need to clarify that this exemption is truly as broad as it should be,'" Sitkowski said.