How exposed is Ireland’s pharma industry?

Washington’s latest tariff moves are more nuanced than headlines suggest – John O’Loughlin unpacks who’s exposed, who’s protected and what exporters must do now to stay competitive

pills all lined up in a row

Despite a turbulent few weeks, there have been developments in US trade policy.

Pharmaceutical tariffs

On 2 April 2026, President Trump announced the outcome of the Section 232 investigation into the pharmaceutical industry and imposed a 100 percent 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 Liechtenstein will only be subject to a 15 percent 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 percent tariff through January 20, 2029.
  • Companies that only enter into onshoring agreements with the US will be subject to a 20 percent tariff through April 1, 2030, upon which time this rate will increase to 100 percent.
  • 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 speciality 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, namely: 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, the White House published a Presidential Proclamation, 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 12:01AM 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 percent 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 percent 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 from US-origin steel, aluminium or copper will attract a lower 10 percent tariff.

Products comprising 15 percent 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 percent ad valorem duty.

Products removed from scope

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

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.

John O’Loughlin is Tax Partner at PwC Ireland