Section 232 pharmaceutical tariffs are now in effect, and WilmerHale says importers still have time to cut their duty exposure. The law firm's advisory, published after the measures kicked in, argues that mitigation strategies remain open to pharmaceutical shippers — even at this late stage.

That matters for a specific reason. Section 232 is the same statute the Trump administration used for steel and aluminium, and it works differently from ordinary trade remedies. It links duties to national security findings rather than market injury, which changes both the politics and the practical levers available to importers.

What does this change for pharma shippers?

The immediate commercial consequence is straightforward. Any company moving pharmaceutical products into the United States now pays the tariff at the border unless it qualifies for an exclusion, an adjustment, or another mitigation path. For forwarders and customs brokers, that means classification work, valuation reviews and origin documentation move to the top of the compliance queue.

WilmerHale's core message: it's not too late. Importers that assumed the door had shut on planning can still consider strategies to reduce the duty burden. The firm frames the moment as one for action rather than resignation.

Why mitigation still matters after the effective date

Tariff planning doesn't stop when tariffs start. That's the mechanism behind the advisory. Duties under Section 232 typically leave room for:

• Product-level exclusions, where importers argue their goods don't threaten national security
• Supply chain and sourcing adjustments that shift origin or production footprints
• Customs structuring — classification, valuation and first-sale strategies that legally lower the dutiable base
• Engagement with the review process as the administration settles the regime's final scope

Each lever carries different timelines and costs. Exclusion processes can take months. Sourcing shifts take longer still, and in pharma, where plants are certified and supply is regulated, switching origin is not a decision anyone makes in a quarter.

The practical question importers should ask now

What does this change for the average pharmaceutical shipper? Two things. First, landed cost. Duties at the border feed straight into the price of imported medicines, ingredients and intermediates. Second, planning posture. Companies that treated the tariffs as a negotiating threat rather than a settled policy now face a live cost line in their import budgets.

The advisory's timing signals that the legal window hasn't closed. Firms with exposure should be running the numbers now: which products the tariffs cover, at what rate, and whether any mitigation route — exclusion, sourcing or customs structuring — beats simply absorbing the cost.

For carriers and forwarders serving the pharma trade, the calculus is quieter but real. Tariffs that raise import costs can rebalance trade flows over time, shifting volumes between lanes and origin countries as manufacturers weigh their options. Nothing in the near term suggests a collapse in pharmaceutical imports — the goods are essential and the alternatives are limited — but the duty regime will shape routing and sourcing decisions through 2025 and beyond.

WilmerHale's bottom line is worth repeating: the tariffs are here, but the mitigation playbook is still open. Importers that engage early — with counsel, brokers and customs data — will pay less than those that wait for the regime to harden around them.