25% Tariff Proposed on Imported Orthopedic Products

The wording of the proposed rule is unambiguous. All “orthopedic or fracture appliances, and parts and accessories thereof and all artificial joints and parts and accessories, thereof” coming from China would be subject to this proposed 25% tariff.

While the U.S. is the largest supplier of orthopedic products around the world, U.S. based suppliers routinely use components which are manufactured in China.

At the just completed American Academy of Orthopaedics Surgeons (AAOS) annual meeting, for example, 38 Chinese origin companies had booths—the most from a country outside the U.S.

They were selling to both the attending physicians AND to other exhibiting companies.

The notice sets in motion a period of public commentary. All written comments are due May 15, 2008. The due date for post-hearing rebuttal comments is May 22, 2018.

Then, if nothing changes, orthopedic products and components and a long list of medical devices (MRIs, CTs, syringes, catheters, for example) and their components coming from China will become more expensive.

Will China retaliate?

And if it does, will the fact that a significant portion of orthopedic products are manufactured in Indiana, the home of Vice President Mike Pence, make this industry particularly vulnerable?

We will stay on top of this and report on all public comment.

The following is a partial list of the medical devices, orthopedic products and other medical products which the U.S. government is proposing to tax.

LIST OF ORTHOPEDIC MEDICAL DEVICES AND RELATED PRODUCTS SUBJECT TO 25% TARIFF

90181300 Magnetic resonance imaging electro-diagnostic apparatus used in medical, surgical, dental or veterinary sciences 90181400 Scintigraphic electro-diagnostic apparatus used in medical, surgical, dental or veterinary sciences 90181940 Electro-diagnostic apparatus for functional exploratory examination, and parts and accessories thereof 90181955 Electro-diagnostic patient monitoring systems 30032000 Medicaments containing antibiotics, nesoi, not dosage form and not packaged for retail 30021300 Immunological products, unmixed, not put up in measured doses or in forms or packings for retail sale 30021400 Immunological products, mixed, not put up in measured doses or in forms or packings for retail sale 30021500 Immunological products, put up in measured doses or in forms or packings for retail sale 30021900 Blood fractions, nesoi 30022000 Vaccines for human medicine 29242957 Diethylaminoacetoxylidide (Lidocaine) 90211000 Orthopedic or fracture appliances, and parts and accessories thereof 90189075 Electro-medical instruments and appliances nesi, and parts and accessories thereof 90189080 Instruments and appliances used in medical, surgical, dental or veterinary sciences, nesi, and parts and accessories thereof 90213100 Artificial joints and parts and accessories thereof 90111040 Stereoscopic microscopes, provided with a means for photographing the image 90111080 Stereoscopic microscopes, other than those provided with a means for photographing the image 90112040 Microscopes for microphotography, microcinematography or microprojection, provided with a means for photographing the image 90119000 Parts and accessories for compound optical microscopes, including those for microphotography, microcinematography or microprojection 90121000 Microscopes other than optical microscopes; diffraction apparatus 90129000 Parts and accessories for microscopes other than optical microscopes, and for diffraction apparatus 90181200 Ultrasonic scanning electro-diagnostic apparatus used in medical, surgical, dental or veterinary sciences 90181300 Magnetic resonance imaging electro-diagnostic apparatus used in medical, surgical, dental or veterinary sciences 90181400 Scintigraphic electro-diagnostic apparatus used in medical, surgical, dental or veterinary sciences 90181940 Electro-diagnostic apparatus for functional exploratory examination, and parts and accessories thereof 90181955 Electro-diagnostic patient monitoring systems 90181975 Printed circuit assemblies for electro-diagnostic parameter acquisition modules 90181995 Electro-diagnostic apparatus nesi, and parts and accessories thereof nesi 90182000 Ultraviolet or infrared ray apparatus used in medical, surgical, dental or veterinary sciences, and parts and accessories thereof 90183100 Syringes, with or without their needles; parts and accessories thereof 90183200 Tubular metal needles and needles for sutures, used in medical, surgical, dental or veterinary sciences, and parts and accessories thereof 90183900 Catheters, cannulae and the like nesi, used in medical, surgical, dental or veterinary sciences, and parts and accessories thereof 90184100 Dental drill engines, whether or not combined on a single base with other dental equipment, and parts and accessories thereof 90184940 Dental burs 90184980 Instruments and apparatus used in dental sciences, nesi, and parts and accessories thereof 90189030 Anesthetic instruments and appliances nesi, used in medical, surgical, dental or veterinary sciences, and parts and accessories thereof 90189060 Electro-surgical instruments and appliances nesi, other than extracorporeal shock wave lithotripters and parts and accessories thereof 90189075 Electro-medical instruments and appliances nesi, and parts and accessories thereof 90189080 Instruments and appliances used in medical, surgical, dental or veterinary sciences, nesi, and parts and accessories thereof 90221200 Computed tomography apparatus based on the use of X-rays 90221300 Apparatus based on the use of X-rays for dental uses (other than computed tomography apparatus) 90221400 Apparatus based on the use of X-rays for medical, surgical or veterinary uses (other than computed tomography apparatus) 90221900 Apparatus based on the use of X-rays other than for medical, surgical, dental or veterinary use 90222100 Apparatus based on the use of alpha, beta or gamma radiations, for medical, surgical, dental or veterinary use 90222980 Apparatus based on the use of alpha, beta or gamma radiations, other than for medical, surgical, dental or veterinary use, nesi 90223000 X-ray tubes 90229005 Radiation generator units 90229015 Radiation beam delivery units 90229025 X-ray generators, high tension generators, desks, screens, examination or treatment tables, chairs and similar apparatus, nesi 90229040 Parts and accessories of X-ray tubes 90229060 Parts and accessories of apparatus based on the use of X-rays 90229095 Parts and accessories of apparatus based on the use of alpha, beta or gamma radiations 90251120 Clinical thermometers, liquid-filled, for direct reading, not combined with other instruments 90261020 Electrical instruments and apparatus for measuring or checking the flow or level of liquids 90269020 Parts and accessories of electrical instruments and apparatus for measuring or checking variables of liquids or gases 90278025 Nuclear magnetic resonance instruments