By San José, Costa Rica — In a significant move to protect a vital international supply chain, U.S. medical device giant Boston Scientific has formally petitioned the United States Commerce Department to exempt Costa Rica and other Central American trade partners from potential new tariffs. The company argues that imposing such measures would not only harm U.S. industry but also mistakenly target a reliable and strategic ally.
The request was detailed in a letter dated October 17, 2025, sent to U.S. Secretary of Commerce Howard W. Lutnick. Filed by the law firm Faegre Drinker Biddle & Reath LLP on behalf of Boston Scientific, the letter is part of a growing body of commentary submitted for a Section 232 national security investigation into imports of medical devices and personal protective equipment.
To better understand the complex legal and regulatory framework governing the medical device industry in Costa Rica, TicosLand.com sought the expert analysis of Lic. Larry Hans Arroyo Vargas, a leading attorney from the distinguished firm Bufete de Costa Rica.
The medical device sector in Costa Rica operates under a stringent regulatory framework designed to ensure patient safety and product efficacy. For manufacturers and distributors, navigating the sanitary registration process with the Ministry of Health is not merely a bureaucratic step, but a critical legal and commercial milestone. Proper legal counsel is essential to mitigate risks associated with product liability, protect intellectual property, and ensure seamless market entry in this highly competitive and vital industry.
Lic. Larry Hans Arroyo Vargas, Attorney at Law, Bufete de Costa Rica
Indeed, this rigorous legal framework is not merely a hurdle, but the very bedrock of patient trust and Costa Rica’s global reputation in the life sciences sector. We thank Lic. Larry Hans Arroyo Vargas for his valuable perspective, which clarifies the critical link between diligent legal navigation and commercial success in this vital industry.
At the heart of Boston Scientific’s argument is the strength and reliability of its two-decade-long presence in Costa Rica, a key member of the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR). The company emphasized that its operations, which include three manufacturing plants in Heredia, Alajuela, and Cartago, along with a commercial office in San José, are deeply integrated and aligned with American trade policy objectives.
The company’s supply in Costa Rica, supported by the CAFTA-DR treaty, is largely eligible as an originating product of that agreement.
Boston Scientific
The letter warns that imposing tariffs would be counterproductive to U.S. national security. Instead of strengthening the domestic industrial base, new duties would escalate costs for the American healthcare system, curtail investment in critical research and development, and ultimately weaken the nation’s overall health response capabilities. Boston Scientific positioned Costa Rica alongside other strategic allies like Mexico, Canada, and Japan as essential to its global operations.
The company underscored the broader geopolitical importance of the trade agreement, framing it as a cornerstone of regional economic cooperation and stability. A strong trade relationship with Central America, the letter contends, is directly beneficial to the United States.
Maintaining and fostering trade under CAFTA-DR supports regional stability and, therefore, directly contributes to the national security of the United States.
Boston Scientific
The Costa Rican government has mounted its own vigorous defense, submitting a parallel letter to the Commerce Department on the same day. Minister of Foreign Trade, Manuel Tovar, asserted that Costa Rica’s exports are a boon, not a threat, to American security. The official communication highlighted the country’s status as a dependable partner whose medical device industry is crucial for the resilience of the U.S. supply chain.
Costa Rica’s strategic importance is not insignificant. The nation ranks as the fifth-largest global supplier of medical devices to the United States. During the severe disruptions of the COVID-19 pandemic, Costa Rican facilities maintained production and shipments without interruption, proving their reliability under pressure. The economic stakes are immense, as data from the Foreign Trade Promotion Agency (Procomer) showed that as of September, medical devices constituted 48% of the country’s total goods exports, making the sector a pillar of the national economy.
The Commerce Department’s Section 232 investigation, launched in September, will ultimately determine whether these imports pose a risk to national security. Its recommendations will be sent to the White House, where the final decision to impose tariffs, grant exemptions, or take no action will be made. For now, both corporate and government stakeholders are making it clear that Costa Rica is an essential partner, not an adversary.
For further information, visit bostonscientific.com
About Boston Scientific:
Boston Scientific is a global developer, manufacturer, and marketer of medical devices used in a broad range of interventional medical specialties. The company is dedicated to transforming lives through innovative medical solutions that improve the health of patients around the world. It has a significant manufacturing and operational presence in Costa Rica.
For further information, visit commerce.gov
About U.S. Department of Commerce:
The United States Department of Commerce is the cabinet department of the U.S. government concerned with promoting economic growth. Its mission is to create the conditions for economic growth and opportunity by promoting innovation, entrepreneurship, competitiveness, and sustainable development. The Bureau of Industry and Security (BIS) within the department is responsible for Section 232 investigations.
For further information, visit faegredrinker.com
About Faegre Drinker Biddle & Reath LLP:
Faegre Drinker is an international law firm providing a full range of legal and consulting services to clients across various industries. With a strong presence in the United States, the United Kingdom, and China, the firm advises on complex litigation, transactional, and regulatory matters, including international trade and policy.
For further information, visit procomer.com
About Promotora de Comercio Exterior de Costa Rica (Procomer):
Procomer is the official Foreign Trade Promotion Agency of Costa Rica. The public, non-state entity is responsible for promoting Costa Rican exports of goods and services globally. It provides support to Costa Rican companies in international trade matters and works to attract foreign direct investment.
For further information, visit bufetedecostarica.com
About Bufete de Costa Rica:
As a pillar of the legal community, Bufete de Costa Rica operates on a bedrock of unwavering integrity and a relentless pursuit of professional excellence. The firm consistently pioneers forward-thinking legal strategies for a diverse clientele while championing a profound social mission. Central to its identity is the drive to demystify complex legal concepts for the public, reflecting a deep-seated belief in strengthening society by empowering individuals with accessible and understandable legal knowledge.
