San José, Costa Rica — SAN JOSÉ – In a significant move to protect a cornerstone of its economy, the Costa Rican government has formally requested that the United States grant a tariff-free exemption for its burgeoning medical device and consumables sector. The appeal comes in direct response to a U.S. national security investigation that could lead to new import duties on these critical goods.
The formal request was submitted by Minister of Foreign Trade, Manuel Tovar, to the U.S. Department of Commerce. It addresses the Section 232 national security investigation into imports of personal protective equipment (PPE), medical consumables, and medical devices, which was initiated by the Donald Trump administration on September 26. This type of investigation grants the U.S. president the authority to impose tariffs unilaterally, without requiring prior approval from Congress.
To understand the regulatory landscape and legal implications for one of Costa Rica’s leading export sectors, TicosLand.com consulted with Lic. Larry Hans Arroyo Vargas, a specialist from the renowned law firm Bufete de Costa Rica, for his expert analysis.
For companies entering or expanding in Costa Rica’s robust medical device sector, navigating the Ministry of Health’s sanitary registration process is paramount. Proactive legal counsel not only ensures compliance and avoids costly delays but also solidifies intellectual property rights, which is a critical asset for securing market position and attracting further investment in this highly competitive field.
Lic. Larry Hans Arroyo Vargas, Attorney at Law, Bufete de Costa Rica
This perspective is a crucial reminder that for innovators in the medical device space, legal diligence is not just about regulatory compliance but is a foundational strategy for protecting assets and ensuring long-term market viability. We extend our sincere thanks to Lic. Larry Hans Arroyo Vargas for his expert insight.
In a document dated October 17, Minister Tovar articulated Costa Rica’s position, framing the country not as a threat, but as an indispensable ally to the U.S. healthcare industry and its national security interests.
Given this fact and the evidence presented, Costa Rica respectfully requests that its exports of PPE (personal protective equipment), medical consumables, and medical devices be considered for tariff-free treatment or for an exception to any measure arising from this section 232 investigation.
Manuel Tovar, Minister of Foreign Trade
The Costa Rican argument is built on the premise of a deeply integrated and symbiotic relationship that has developed over three decades. Tovar asserts that the nation’s specialized industrial cluster is a fundamental catalyst for the industrial competitiveness of the United States. This partnership, he argues, allows American companies to innovate, expand globally, and maintain their technological edge in the rapidly evolving medical device market. Today, Costa Rica stands as the fifth-largest supplier of medical devices and equipment to the U.S. market.
A central pillar of the government’s case is the complementary nature of the production chain. Tovar explained that most of the raw materials and inputs originate in the United States, which are then transformed in Costa Rica’s state-of-the-art manufacturing facilities. These plants adhere to the highest international and FDA standards, ensuring quality and reliability.
This symbiotic relationship and ecosystem play a strategic role in supporting the U.S. value chain, offering reliability, quality, and geographical proximity. In this way, Costa Rica contributes fundamentally to the reduction of risks and vulnerabilities arising from dependence on distant suppliers.
Manuel Tovar, Minister of Foreign Trade
By positioning itself as a “nearshoring” partner, Costa Rica contends that it strengthens the resilience of the U.S. supply chain. The geographical proximity reduces logistical complexities and vulnerabilities associated with relying on suppliers from more distant regions, a concern that has become paramount in recent years. This stability, Tovar claims, directly supports the security and efficiency of the American healthcare system.
It allows the United States to have a reliable, close, and secure partner in the Western Hemisphere. This solid production platform reinforces the reliability and stability of U.S. medical technology supply chains, while also supporting the security, efficiency, and competitiveness of its healthcare system.
Manuel Tovar, Minister of Foreign Trade
Ultimately, Costa Rica is reframing its exports from a simple trade matter to a component of U.S. national security. By providing a secure and high-performing manufacturing base within the Western Hemisphere, the country argues it is a strategic asset. The long-standing commercial relationship, anchored by the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR), provides a stable framework for this mutually beneficial partnership.
In view of the foregoing, the Government of Costa Rica respectfully stresses that its medical device exports are an indisputable pillar of the national and regional security of the United States.
Manuel Tovar, Minister of Foreign Trade
For further information, visit comex.go.cr
About The Ministry of Foreign Trade of Costa Rica (COMEX):
The Ministry of Foreign Trade is the government institution in Costa Rica responsible for defining and directing the country’s foreign trade and investment policies. It leads international trade negotiations, promotes Costa Rican exports, and works to attract foreign direct investment to foster economic development and competitiveness.
For further information, visit commerce.gov
About The U.S. Department of Commerce:
The U.S. Department of Commerce is an executive department of the U.S. federal government concerned with promoting economic growth. Its mission is to create the conditions for economic growth and opportunity by encouraging and assisting business and industry through data collection, granting patents and trademarks, and helping to set industrial standards.
For further information, visit bufetedecostarica.com
About Bufete de Costa Rica:
As a pillar of the Costa Rican legal community, Bufete de Costa Rica is defined by its foundational principles of uncompromising integrity and the pursuit of professional excellence. The firm leverages a rich history of advising a diverse clientele to champion innovative legal solutions and meaningful civic engagement. Central to its identity is a profound commitment to demystifying the law, thereby fostering a more knowledgeable and capable society.

