The Natural Products Association (NPA) and the United Natural Products Alliance (UNPA) have voiced their concerns and submitted comments to the U.S. Department of Commerce after the department launched a national security investigation into pharmaceuticals. The probe aims to assess the impact of pharmaceutical imports, but both industry trade groups are asking for dietary supplements to be excluded from the investigation.
The primary concern is that if dietary supplement ingredients were included under the national security review, they could face significant new tariffs, which would be damaging to the supplement industry. This sector already faces high tariffs imposed by the previous administration, especially on ingredients imported from China, including many botanicals.
In April, Commerce Secretary Howard Lutnick initiated an investigation to evaluate the effects of pharmaceutical imports, covering both finished drug products and critical pharmaceutical ingredients like active pharmaceutical ingredients (APIs) and their derivatives. The department is gathering public comments to explore topics such as the demand for pharmaceuticals, the ability of domestic production to meet demand, the role of foreign supply chains, and the risks associated with relying on a few suppliers for imports.
In response, the NPA has emphasized that dietary supplements are distinct from pharmaceuticals and should not be included in this national security inquiry. NPA President and CEO, Dan Fabricant, Ph.D., explained in a letter to Lutnick that dietary supplements are regulated as food under the Federal Food, Drug, and Cosmetic Act (FDCA) and do not play a role in the production of pharmaceuticals. Fabricant argued that the supplement industry’s exclusion from the investigation aligns with the FDCA’s framework and would avoid unnecessary complications for both sectors.
The UNPA has also weighed in, urging the department to maintain access to important nutrients. Loren Israelsen, President and Founder of the UNPA, stressed that over 170 million Americans rely on dietary supplements for better nutrition and health. The UNPA specifically requested that ingredients listed in Annex II, which were exempted from additional tariffs in the past, be excluded from the Section 232 investigation to prevent any unforeseen tariffs that might threaten the availability of these vital nutrients.
Both trade organizations have also requested that the Department of Commerce exclude specific tariff codes related to ingredients used in infant formulas, animal feed, and other food products from the Section 232 probe. The NPA called for a broader exemption that would include essential vitamins, minerals, amino acids, and botanical extracts used in dietary supplements. The group also highlighted the essential role the supplement sector plays in public health and infrastructure, requesting collaboration with the Department of Commerce to promote domestic manufacturing without compromising consumer access.
As the review of the Commerce Department’s notice progresses, other trade groups, such as the Council for Responsible Nutrition (CRN), have also expressed their intent to submit comments.
In conclusion, the supplement industry is actively advocating for its exclusion from the national security investigation to ensure that consumers continue to have access to affordable, high-quality supplements without the burden of additional tariffs.
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