Important Update: Changes to Tariffs for Materials Imported into the USA (February)
February 28, 2025
We would like to inform you about recent changes to tariffs for materials imported into the USA where the country of origin is designated as China or Hong Kong. Effective 04 February 2025, an additional ad valorem 10% tariff will be applied to all items originating from these countries. This change is in line with the Executive Orders announced by the US Government on 01 February 2025.
High Level Summary:
| Query | Response |
| Tariff Application | An additional ad valorem 10% tariff will be applied to material which is imported into the USA where the country of origin is designated as China or Hong Kong. |
| Country of Origin Designation | For material imported into the USA, the country of origin will be determined by the site of manufacture of the item.
For pharmaceuticals, the country of origin is determined by the site of manufacture for the active pharmaceutical ingredient (API). This is consistent with the position of U.S. Customs and Border Protection (CBP) prior to the implementation of the new tariffs. |
| HTS Codes Impacted | All Harmonized Tariff Schedule (HTS) codes are affected.
For example, active pharmaceuticals under HTS codes 3002, 3003, 3004 will now have an additional ad valorem 10% tariff applied. The additional 10% tariff will apply to placebo items also and will increase the tariff to between 20% to 40% depending on the characteristics (HTS code) of the placebo. |
| Are There Any Exemptions? | Following clarification with the CBP, Almac has been advised that there are no exemptions for pharmaceuticals and medical devices. |
Next Steps:
| Query | Response |
| Almac acting as Importer of Record (IOR) | Almac will retain the responsibility for the payment of the tariff, which will be passed on to the client. The client remains responsible for providing an accurate commercial value to Almac for each item to be imported.
Almac will contact the client when serving as IOR (Importer of Record) prior to providing the green light to ship. Where China or Hong Kong is noted as the country of origin for any items, Almac will advise of the value of the tariff which will be applicable. Almac will require written confirmation from the client to proceed with each shipment and to confirm acceptance of the additional tariff. Upon receipt of payment request from Almac’s Broker, Almac will issue an invoice to the client for immediate payment. Important note: It is imperative that any additional tariffs must be considered as part of the client’s study budget. |
| Client acting as Importer of Record (IOR) | It is crucial that you understand and plan for the impact of these tariffs within your study budget. Almac will not be liable for delays or shipment impacts resulting from the new tariff when using Almac’s courier account, when the client is acting as IOR. |
| Additional considerations | You should conduct a thorough review to identify the country of origin of items used within your clinical study to identify any budget impact which may be caused by the implementation of these tariffs. |
We understand that these changes may impact your clinical supply budgets. As this is an evolving situation, our team is here to support you in navigating these new regulations and ensuring compliance. This should not be construed as legal advice, and we would recommend that you seek independent advice specific to your circumstances from your legal or professional advisers.
If you have any questions or require further assistance, please contact your dedicated Clinical Supply Manager.