WASHINGTON, April 14, 2026 /PRNewswire/ — Today, Antonio Ortiz-Mena, CEO of AOM Advisors, and Christopher G. Sheeron, CEO of Action for Health, released “Critical Care: Protecting U.S. Medical Device Leadership Through Targeted Section 232 Action,” a new white paper providing a comprehensive analysis and roadmap for the U.S. government as it nears a final decision on the Section 232 national security investigation into medical device imports.
The report arrives at a critical juncture for the $280 billion domestic industry, which employs 2.8 million Americans and accounts for 40% of the global market share. With the Supreme Court’s February 20, 2026, ruling in Learning Resources, Inc. v. Trump invalidating IEEPA-based tariffs, Section 232 has emerged as the primary instrument for the administration to secure critical healthcare supply chains, warranting strategic implementation.
“The medical device sector is an American powerhouse where 70% of technology sold in the U.S. is already produced across 16,000 facilities domestically,” said Ortiz-Mena. “The goal of Section 232 should not be to rebuild from scratch, but to strategically reinforce existing strengths without inadvertently crippling the providers and patients who rely on these tools.”
The paper argues for a tactical approach to tariffs on medical devices, to curtail the risk of destabilizing a complex ecosystem. The authors instead propose a two-tier application:
- Tier 1: Immediate Action – Apply tariffs to Personal Protective Equipment (PPE) where domestic capacity is already positioned to scale.
- Tier 2: Conditional Implementation – Condition tariffs for essential consumables and complex diagnostics on demonstrated domestic capacity expansion to prevent critical shortages.
Ortiz-Mena and Sheeron highlight how these tariffs, if implemented incorrectly, will threaten U.S. hospitals and patients, noting that with Medicare reimbursing hospitals at just 83 cents on the dollar, broad or abrupt tariffs could trigger a “pass-through” event that raises costs for patients before domestic alternatives are fully available to meet demand.
While the 232 investigation targets vulnerabilities in non-allied supply chains, it identifies the Tijuana–San Diego corridor, which is North America’s largest medical device cluster, as an essential partner. The authors argue that Section 232 measures should apply pressure to adversary-sourced supply chains while protecting USMCA-qualifying goods, as otherwise it effectively penalizes the very reshoring efforts the administration seeks to encourage.
Key Findings at a Glance:
- Market Leadership: The U.S. holds 40% of the global medical device market.
- Domestic Resilience: 70% of medical tech used in the U.S. is manufactured at home.
- Economic Risk: Supply cost movements of even 50 basis points represent significant margin events for major U.S. hospital systems.
- Strategic Reshoring: Mexico is now the leading exporter of medical devices to the U.S., serving as a primary destination for production shifted out of China.
The full white paper, including detailed policy recommendations and economic modeling, is available here.
Action for Health is a national nonprofit advocacy organization working to ensure fair outcomes for critical healthcare issues. The organization educates policymakers, the media, and concerned citizens about policies, laws, and regulations that are important to patients.
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SOURCE Action for Health
