Industrial Policy & Trade Monitor· 2667 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.

On 27 July 2025, President Trump and European Commission President Ursula von der Leyen reached political agreement at Turnberry, Scotland, on a Framework Agreement on Reciprocal, Fair and Balanced Trade. The framework was formalised in a Joint Statement published on 21 August 2025 by the White House and DG TRADE. The deal establishes a 15% all-inclusive (MFN + Section 232) US tariff ceiling on the vast majority of EU originating goods — including autos, pharmaceuticals, semiconductors, lumber, and chemicals — replacing the threatened 20-30% reciprocal tariff trajectory under EO 14257 (April 2025). Steel and aluminium are excluded from the 15% ceiling and remain at the 50% Section 232 rate pending negotiation of a quota solution. In return, the EU commits to: (i) eliminate tariffs on all US industrial goods, (ii) preferential market access for a wide range of US agricultural and seafood products, (iii) suspension of its rebalancing countermeasures under Reg 2025/778 (suspension effective 7 August 2025), (iv) expected energy offtake of $750bn (LNG, oil, nuclear) through 2028, (v) at least $40bn in US AI chip purchases, and (vi) facilitation of $600bn in additional EU corporate investment into the US through 2028. Effective from 1 September 2025, the US applies MFN-only treatment (no 15% top-up) to: aircraft and parts, generic pharmaceuticals and ingredients, chemical precursors, cork, and certain unavailable natural resources. The framework is not legally binding but anchors the bilateral architecture; it is the largest-economy ART-programme deal alongside US-UK, US-Japan, US-Korea, US-Taiwan, and US-Indonesia.

Ireland's Screening of Third Country Transactions Act 2023 (Act No. 28 of 2023), signed into law on 31 October 2023 and commenced on 6 January 2025 via S.I. No. 651 of 2024, establishes Ireland's first-ever mandatory inbound FDI screening regime. The Act empowers the Minister for Enterprise, Tourism and Employment to assess, condition, or prohibit transactions by third-country investors (non-EU/EEA/Switzerland) exceeding a EUR 2 million cumulative threshold in targets operating across critical infrastructure, critical technologies, dual-use items, supply of critical inputs, sensitive personal data, and media freedom. A 90-day standstill period applies during Ministerial determination, with criminal sanctions and transaction-voiding powers available for non-compliance.

Bureau of Industry and Security final rule (88 FR 46071, Doc 2023-15343) adding four entities to the Entity List effective July 18, 2023. Intellexa S.A. (Greece) and Intellexa Limited (Ireland) — the corporate architecture behind the "Predator" commercial spyware platform — and Cytrox Holdings Zrt. (Hungary) and Cytrox AD (North Macedonia) — the developer of the underlying spyware technology — were listed for "trafficking in cyber exploits used to gain access to information systems, thereby threatening the privacy and security of individuals and organizations worldwide." All items subject to the EAR require a license with a presumption-of-denial review policy for all four entities, effectively cutting off access to US-origin hardware, software, and technology.