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AHPA submits comments to U.S. Department of Commerce Section 232 investigation
May 7, 2025
The American Herbal Products Association (AHPA) has submitted comments to a request by the U.S. Department of Commerce Industry and Security Bureau (the “Bureau”), pursuant to an investigation under Section 232 of the Trade Expansion Act of 1962 (“Section 232”). Under this authority, the Bureau investigates the effects on national security of imports of covered commodities and issues a recommendation to the President, who may then enact a wide range of import controls, including additional duties, quotas, embargoes, or the creation of license fee systems.
In the comments, AHPA focuses on common and essential dietary ingredients found in Annex II to Executive Order 14257 (“Annex II”). Annex II exempts certain commodities defined under the Harmonized Tariff Schedule from a system of reciprocal tariffs created in the executive order. Per conversations with the U.S. Trade Representative, AHPA understands that all commodities in Annex II are either under prior import controls such as those authorized by Section 232, or are under investigation under Section 232 and will likely be placed under some form of import control.
AHPA's comments reflect that these ingredients in Annex II, such as vitamins and amino acids, play a vital role in the formulation of many dietary supplements, alongside uses in pharmaceutical, animal feed, conventional food and personal care product settings. AHPA discourages any recommendation of Section 232 controls for these valuable commodities, and emphasizes the challenges, hardships and limitations of possible domestic manufacturing of such commodities under circumstances of import controls. AHPA instead encourages the consideration of alternate, positive incentives for a diverse supply chain, such as direct federal support for domestic production.
“This is all stick and no carrot for commodities that require tremendous infrastructure to be viably produced anywhere”, said Robert Marriott, AHPA Director of Regulatory Affairs. “Positive incentives, not tariffs are the best and only path to domestic, scaled manufacturing.”
AHPA holds a general position of opposition to wide-reaching country-scale tariffs; the organization will continue to advocate for the relaxation and removal of these regimes where they affect the dietary supplement and herbal products communities.
