Tariff Relief for Orthotic & Prosthetic Devices & Manufacturing Components/Materials

The American Orthotic and Prosthetic Association (AOPA) is actively communicating with policy makers and elected officials regarding the consequential impact of tariffs on medical devices dispensed to millions of Americans living with limb loss, limb difference, and orthopedic mobility-limiting conditions. We join our colleagues in the medical device industry in calling for the continuation of existing and future tariff relief in order to maintain access to clinically necessary and appropriate orthotic and prosthetic care. 

Orthotic and prosthetic patients in every state depend on a reliable network of supply chain distributors, manufacturers and fabricators, and patient care providers. Tariffs will have an impact on each of these individual sectors. When considered collectively, the combined tariffs will cause exponential cost increases. This may reduce access to critically needed healthcare services and may cause unsustainable financial harm to patient care providers that receive reimbursement amounts previously determined by the Federal Government without any financial consideration for tariffs. 

AOPA agrees with a model that incorporates zero for zero reciprocal tariffs on materials used to facilitate the fabrication and delivery of orthotic and prosthetic medical devices. This model, which has been suggested by representatives of the Advanced Medical Technology Association (AdvaMed), would use existing humanitarian-based tariff exemptions such as those represented in section 9021.39.000 of the Harmonized Tariff Schedule of the United States (HTSUS), the Florence Agreement and the associated Nairobi Protocol, to provide essential relief to healthcare providers, manufacturers, and product suppliers, including those that make up the orthotic and prosthetic profession. 

AOPA supports efforts to ensure that the United States is treated equitably and fairly in relationships with its foreign trade partners and believes a policy of zero for zero reciprocal tariffs for products and materials associated with the provision of healthcare services, including orthoses and prostheses, allows for the continued provision of necessary and appropriate care without incurring unsurmountable financial burdens resulting from tariffs on medical devices, components, and raw materials. 

AOPA Emphasizes Patient Access to Care When Urging the Department of Commerce to Exclude Custom O&P in National Security Probe

AOPA submitted comments on October 17, 2025, to the U.S. Department of Commerce regarding the Section 232 National Security Investigation on Imports of Personal Protective Equipment (PPE), Medical Consumables, and Medical Equipment (BIS-2025-0248) urging them to exclude custom O&P in their national security probe.

AOPA urged the Bureau of Industry and Security (BIS) to exclude orthoses and prostheses from this investigation, emphasizing that they are custom-fabricated, patient-specific medical devices rather than mass-produced equipment like PPE or consumables. We explained that O&P care is a highly specialized, clinical process involving a multidisciplinary team of rehabilitation professionals. Unlike other medical devices, every prosthesis and orthosis are custom fit, assembled, and delivered in the U.S., meaning they pose no realistic national security risk.

We argued that concerns over foreign supply chains, subsidies, or export restrictions are largely irrelevant to O&P, since imports of O&P components represent a negligible volume and are not subject to predatory trade practices. We also warned that imposing tariffs, quotas, or trade restrictions could increase provider costs within a fixed Medicare reimbursement system, ultimately harming patient access to essential care.

In closing, we reaffirmed O&P’s commitment to patient-centered, evidence-based care and cautioned that including O&P devices in the Section 232 investigation could have unintended consequences for veterans, service members, and millions of Americans living with limb loss or difference. We concluded by stating that these were the reasons we strongly recommend O&P devices be excluded from the investigation to avoid disrupting clinical care and patient outcomes.

Read AOPA’s comment letter.

If you have any questions, contact Joe McTernan, Director of Health Policy and Advocacy at jmcternan@AOPAnet.org.