Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

On 2 April 2026 President Trump issued a Presidential Proclamation under Section 232 of the Trade Expansion Act of 1962 ("Adjusting Imports of Pharmaceuticals and Pharmaceutical Ingredients into the United States") imposing a 100% ad valorem tariff on imports of patented pharmaceutical products listed in the FDA Orange Book and Purple Book, together with the active pharmaceutical ingredients (APIs) and key starting materials used to make them. The base rate takes effect at 12:01 a.m. EDT on 31 July 2026 for the 17 manufacturers identified in Annex III, and on 29 September 2026 for all other companies. The proclamation adopts findings of the Section 232 investigation initiated by the Department of Commerce on 14 April 2025 into pharmaceuticals and APIs as a national- security supply-chain risk. The instrument is structured around a multi-tier rate ladder rather than a flat tariff: concessionary 15% rates for EU/Japan/South Korea/Switzerland/Liechtenstein under reciprocal-deal tracks, 10% for the UK with a pathway to 0% under the pending UK pharmaceutical agreement, a "+20%" surcharge for companies operating under a Commerce-approved onshoring plan (until 2 April 2030), and a 0% pathway for companies that combine an approved onshoring plan with an MFN-pricing agreement with HHS (until 20 January 2029). Generics, biosimilars and their ingredients, orphan drugs, nuclear medicines, plasma-derived therapies, fertility treatments, and cell/gene therapies are carved out.

President Trump signed a Presidential Proclamation on 20 February 2026 invoking Section 122 of the Trade Act of 1974 (19 U.S.C. § 2132) to impose a temporary 10% ad-valorem import surcharge on articles imported into the United States, effective 12:01 a.m. EST on 24 February 2026. The proclamation was issued within hours of the US Supreme Court's 20 February 2026 ruling in Learning Resources, Inc. v. Trump, which held that the International Emergency Economic Powers Act (IEEPA) does not authorize the president to set tariffs and vacated the IEEPA-based reciprocal-tariff regime previously in effect. The Section 122 surcharge is statutorily limited to 150 days (terminates 24 July 2026 absent Congressional extension) and the statute caps any such surcharge at 15% ad valorem. Goods qualifying as USMCA originating from Canada or Mexico are exempt; CAFTA-DR textile/apparel articles meeting specified rules of origin are exempt; and a substantial product-exception list excludes critical minerals, energy products, certain pharmaceuticals, electronics, vehicles, aerospace products, specified agricultural goods, and goods already subject to Section 232 duties (the Section 122 duty does not stack on Section 232).

President Trump signed Executive Order 14257 on 2 April 2025 declaring a national emergency over US trade deficits and imposing a baseline 10% ad-valorem tariff on imports from nearly all trading partners effective 5 April, with higher country-specific "reciprocal" rates effective 9 April. The rate schedule was constructed from a formula tied to bilateral goods-trade deficits and ranged from 10% (UK, Singapore, Brazil, Australia, others) through 20% (EU), 24% (Japan), 25% (Korea), 32% (Taiwan, Indonesia, Switzerland), 34% (China, later raised to 84% then 125% during the April escalation), 46% (Vietnam), 49% (Cambodia). Multiple subsequent EOs paused the country-specific rates for 90 days for non-China destinations on 9 April while keeping the 10% baseline, pending bilateral negotiations.

Switzerland's Federal Council promulgated the Verordnung über die Mindestbesteuerung grosser Unternehmensgruppen (Mindestbesteuerungsverordnung, MindStV; French: OIMin), SR 642.161, AS 2023 841, on 22 December 2023, with effect from 1 January 2024. The ordinance enacts a 15% Qualified Domestic Minimum Top-up Tax (QDMTT — Ergänzungssteuer) on Swiss constituent entities of MNE groups with consolidated annual revenue ≥ EUR 750 million, enacted under the temporary constitutional authority granted by Swiss voters in a popular referendum on 18 June 2023 (78.5% yes, Art. 129a BV). The Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) were deliberately deferred to subsequent ordinance amendments, targeting FY 2025 phasing. The Swiss Federal Tax Administration (ESTV / AFC) is the administering authority; first QDMTT returns and GloBE Information Returns due 30 June 2026.

On 4 March 2022 Switzerland's Federal Council adopted a total revision of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), taking effect the same day at 18:00, to fully implement the EU's sanctions packages of 23 and 25 February 2022. The revision bans export of all dual-use goods to Russia regardless of end use or end user, bans export of goods that could contribute to Russia's military or technological strengthening or its defence and security sector, and prohibits export of specified goods and services to the oil sector, as well as goods for aviation, space and oil-refining/gas-liquefaction use.

Russia Federal Law No. 127-FZ of 4 June 2018 "On measures (countermeasures) regarding the unfriendly actions of the United States of America and other foreign states" establishes the statutory authority under which the President and Government of the Russian Federation may impose counter-measures against states that engage in "unfriendly actions" toward Russia. The law enumerates permissible countermeasure categories — including import/export prohibitions, restrictions on foreign participation in Russian state procurement, suspension of international cooperation obligations, and prohibition of foreign-company services and transactions — and delegates implementation authority to the President (primary) and Government. It entered into force on the day of official publication (4 June 2018) and is the foundational parent statute for every major Russian counter-sanctions presidential decree and government resolution subsequently issued, including the gas-for-roubles payment regime, capital controls, parallel- imports authorisation, and asset-confiscation counter-mechanism.

The Federal Act of 22 March 2002 on the Implementation of International Sanctions (Embargogesetz / EmbG, SR 946.231), in force 1 January 2003, is Switzerland's foundational enabling statute authorising the Federal Council to issue coercive-measure ordinances implementing UN Security Council mandatory sanctions (under UN Charter Art. 25 obligations accepted upon Switzerland's 2002 UN accession), OSCE sanctions decisions, and — via the progressive EU-tracking clause — the sanctions of Switzerland's most important trading partners, primarily the EU. The State Secretariat for Economic Affairs (SECO) administers all resulting ordinances; FINMA supervises financial-sector compliance and FOEN supervises trade-in-goods compliance. The EmbG is the parent authority for Switzerland's entire portfolio of approximately 25 country-specific sanctions ordinances, including the Ukraine/Russia ordinance (SR 946.231.176.72 implementing EU Russia packages 1-19+), the Iran ordinance (SR 946.231.143.6), the DPRK ordinance (SR 946.231.127.6), the Myanmar ordinance (SR 946.231.157.5), and the Belarus ordinance (SR 946.231.116.9).