President Trump unveils sweeping new pharmaceutical tariffs, reshapes section 232 steel & aluminium regime

Pharmaceutical Tariffs 

On 2 April 2026, President Trump announced the outcome of the Section 232 investigation in the pharmaceutical industry and imposed a 100% tariff on patented pharmaceutical products and ingredients, due to come into effect in 120 days for large companies and 180 days for smaller companies. 

While such an announcement will no doubt cause concern with respect to pharmaceutical exporters, there are a significant number of exemptions which will limit the impact that this will have on EU and Irish companies, as follows:

• Pharmaceutical products from the EU, Japan, Korea, Switzerland and Lichtenstein will only be subject to a 15% tariff. 

• Products from the UK will be subject to a lower tariff (rate TBC). 

• Companies that have already entered or subsequently enter into the Most Favoured Nation (MFN) pricing agreements and onshoring agreements with the US Administration will be subject to a 0% tariff through January 20, 2029. 

• Companies that only enter into onshoring agreements with the US Administration will be subject to a 20% tariff, through April 1, 2030, upon which time this rate will increase to 100%.

• Generic pharmaceutical products, biosimilars, and associated ingredients are not subject to tariffs at this time, but this will be reassessed in one year.

• Orphan drugs, drugs for animal health, and certain other specialty pharmaceutical products will be exempt, if they are from trade deal countries or meet an urgent US public health need.

As noted in the Irish Times, fourteen of the largest pharmaceutical manufactures have entered into MFN agreements with the US Administration, including: Pfizer, AstraZeneca, EMD Serono, Novo Nordisk, Eli Lilly, Amgen, Boehringer Ingelheim, Bristol Myers Squibb, Genentech (Roche), Gilead Sciences, GlaxoSmithKline, Merck (known in Ireland as MSD), Novartis and Sanofi.

For such companies, the immediate impact of this announcement will be limited. Notwithstanding these fourteen companies, other EU and Irish pharma exporters who have not signed agreements with the US Administration must assess the impact which this will have on their supply chains and take necessary steps to prepare for the full implementation of these measures. 

Steel and Aluminium Tariffs

On 2 April, a Presidential Proclamation was published entitled "Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper Into the United States." The Proclamation introduces significant modifications to the existing Section 232 tariff regime for metals imports into the US, with changes taking effect from 12:01 a.m. EDT on 6 April 2026. 

The key points with respect to this announcement are as follows: 

• Tariffs now assessed on full customs value

Section 232 tariffs will now apply to the full customs value of covered aluminium, steel, and copper articles and their derivative products, regardless of actual metal content. This is a notable change from the prior approach, which in certain cases applied duties only to the metal portion of an article.

• New tiered tariff rate structure 

Articles made entirely or almost entirely of aluminium, steel, or copper (e.g. steel coils, aluminium sheet) will be subject to a flat 50% ad valorem duty on their full value. The list of applicable commodity codes is found in Annex I-A

Derivative articles substantially made of these metals will be subject to a flat 25% ad valorem duty on their full value. The list of applicable commodity codes is found in Annex I-B  

Products manufactured abroad but made entirely with US-origin steel, aluminium, or copper will attract a lower 10% tariff. 

Products comprising 15% or less steel, aluminium, or copper by weight will no longer be subject to Section 232 metals tariffs. 

• Russian aluminium

All aluminium articles where any amount of primary aluminium was smelted or cast in Russia remain subject to a 200% ad valorem duty.

• Products removed from scope

A number of derivative products have been removed from the Section 232 tariff regime entirely, as set out in Annex II to the Proclamation (Annex II).

Given the significant changes to the Section 232 tariff regime, affected exporters and importers should review this carefully to identify impacts to the supply chain. 

Other Ongoing Matters

Notwithstanding the above announcements and our update from 2 April, there still remains a number of key outstanding matters with respect to US trade policy and upcoming announcements, including:

• The outcome of Section 232 investigation on commercial aircraft, jet engines, and associated parts.

• The implementation of US CBPs CAPE system to facilitate the refunds of IEEPA tariffs charged in 2025 and 2026. 

• The reports to be issued under the recent Section 301 investigations, into excess supply and forced labour prohibition practices of economies from which over 99% of U.S. imports originate.

Any actions taken in respect of the above matters should be monitored closely and will continue to be a key focus area over the coming months as they continue to shape US trade policy. 

US Specific Advice

PwC is here to support you by providing clear, US-centric guidance on tariffs and trade issues. We work directly with our PwC US colleagues to interpret these kinds of developments, assess impacts, and deliver practical advice that reflects current US policy and enforcement risks. This ensures you receive consistent, actionable input for your business grounded in local US expertise.

We’re here to help you

Keeping up to date with US trade policies, trade agreements and new and existing tariff reviews which may lead to further tariff measures is crucial to assessing the risk to your supply chain and the impact these tariffs may have. Understanding your product portfolio and the impact that tariffs may have on your imports is an important first step. We are here to support your business with this analysis and navigating these choppy waters.