Tariffs and clinical trial supply: what procurement teams should plan for in 2027

If you're budgeting and sourcing for studies that start in 2027, you're planning around trade rules that have changed more in the past 18 months than in the decade before. US tariffs have been introduced, challenged in court, struck down, replaced and replaced again.

For procurement teams and vendor managers, no single tariff is the real problem. The problem is that a study you sign off now could run until 2030, and nobody can promise what the rules will look like by then.

That doesn't mean waiting to see what happens. The teams that come through this best will be the ones who build tariff risk into their plans from the start. Here's what 2026 has taught us, what's worth watching in 2027, and how to set your study up to cope with whatever comes next.

What changed in 2026, and why does it matter for 2027?

Quite a lot, and quickly. Much of it is still settling, which is exactly why it matters for anyone planning next year's studies.

In February 2026, the US Supreme Court ruled that tariffs imposed under emergency powers (IEEPA) were unlawful. The administration replaced them with a temporary surcharge under a different law, Section 122, which expired in July. [1] [2]

At the end of July, new Section 232 tariffs of up to 100% took effect on patented pharmaceuticals and their ingredients. The good news for trial sponsors is that investigational products used in clinical research are unlikely to be affected. [3]

Equipment is a different matter. A separate Section 232 investigation into medical equipment, devices and consumables opened in September 2025 and, as of September 2026, still hasn't reached a decision. [2] Some consumables from China already carry heavy duties too, including 100% on syringes and needles and, since January 2026, 100% on medical gloves. [2]

So while the drug in your trial may be protected, much of what surrounds it may not be.

What should you keep an eye on in 2027?

We're not going to pretend we know where tariffs will be in a year's time. Nobody does. What we can say is that several decisions already in motion are likely to land during 2027, and each could affect your equipment budget.

The medical device decision
This is the big one for trial equipment. If the Section 232 investigation leads to new tariffs on devices and consumables, it could affect a wide range of the equipment and ancillaries a typical study relies on.

How the pharmaceutical tariffs bed in
US Customs issued updated guidance on the new pharmaceutical tariffs in September 2026. [4] Investigational products look unlikely to be caught for now, but it's worth checking how that guidance is applied in practice once shipments are flowing.

Duties on Chinese consumables
Heavy duties on items such as syringes, needles and gloves are already in place, and a new baseline duty under Section 301 took effect in July 2026. [2] If your kitting relies on low-cost consumables, sourcing is worth a fresh look.

The courts
Legal challenges to this year's tariffs are still working their way through the system, including an appeal over the Section 122 surcharge. [5] The outcomes may affect what importers end up paying.

You don't need to predict how any of these play out. You do need suppliers who are watching them and will tell you early when something changes.

What about wider global disruption?

Tariffs aren't the only thing that can hold up a shipment. Conflict and political instability in different parts of the world affect clinical trial supply too, often with little warning. Shipping routes get diverted, airspace closes, transit times stretch and freight costs rise. Sanctions and export controls can change overnight, and that can affect what equipment is allowed to go where, and who it can be sold to.

Nobody can plan for every one of these events. What you can do is make sure your supply chain doesn't depend on a single route or a single point of failure. Equipment held in more than one region, alternative shipping options and an Importer and Exporter of Record who keeps up with sanctions and export rules all make it far easier to keep a study moving when something unexpected happens.

Why does this matter for trial equipment?

Because equipment crosses borders far more often than people expect.

A single study might ship equipment to sites at set-up, send resupplies and replacements during the trial, and bring everything back at close-out. Multiply that by 15 or 20 countries and you have hundreds of customs entries over the life of a study. Each one needs the right classification, the right paperwork and the right duty paid.

When tariff rules change mid-study, any of those entries can go wrong. A shipment gets held at customs. A duty bill nobody budgeted for arrives. A site misses its initiation visit because the kit it needs is sitting in a warehouse at the border. For procurement, it's exactly the problem you vetted your suppliers to avoid.

What does an Importer of Record actually do?

An Importer of Record (IoR) is the legally recognised party responsible for making sure imported goods comply with the destination country's rules. For clinical trial equipment, that covers:

• Classifying each item correctly for customs
• Paying the right duties and taxes
• Securing any permits and certifications needed
• Handling local customs entry and documentation
• Keeping up with regulations as they change

That last point has become far more important. When tariffs shift every few months, your IoR is the one who has to notice, understand what it means for your equipment, and adjust before your next shipment goes out.

How can the right IoR protect your study from tariff changes?

A capable IoR partner won't make tariffs go away. It can stop them turning into delays and surprise costs.

Getting classification right first time
Most customs holds start with paperwork. An IoR that knows clinical trial equipment well classifies it correctly, so shipments clear without queries.

Keeping track of the rules for you
Staying current across dozens of countries is a full-time job. It shouldn't fall to your study team.

Fewer border crossings
Equipment held in regional warehouses closer to your sites crosses fewer borders, which means fewer chances for a new tariff or a customs query to catch it.

Planning for the return journey
Rented equipment has to come back out of the country at the end of a study. Planning exports at the start avoids problems at close-out, when there's least appetite for them.

One partner instead of many
Using a different local broker in every country means multiple contracts, multiple points of failure and nobody with the full picture. A single IoR across all your countries gives you one point of contact and one standard.

What should procurement ask an equipment supplier about tariffs?

If you're vetting suppliers or reviewing an existing one, these questions will tell you a lot:

• Do you act as Importer of Record yourselves, and in which countries?
• How do you keep customs classifications up to date when the rules change?
• How are duties and taxes shown in your quotes, and what happens if rates change mid-study?
• Where do you hold stock, and how close is it to our sites?
• What's your record for delivering before site initiation visits?
• If a shipment is held at customs, who deals with it and how quickly?
• If a shipping route is disrupted, what's your backup plan?

A supplier that answers these clearly and confidently has probably already dealt with the problem. One that can't is likely to hand the problem back to you.

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