Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China
February 5, 2025
Action Summary
- Authority: Action taken under the Constitution and laws such as the International Emergency Economic Powers Act, National Emergencies Act, Trade Act of 1974, and section 301 of title 3, United States Code.
- Amendment Focus: Revises the Executive Order of February 1, 2025, regarding duties imposed to address the synthetic opioid supply chain linked to the People’s Republic of China.
- Key Amendment Detail: Replaces subsection (g) of section 2 to specify that duty-free de minimis treatment for eligible covered articles will cease once the Secretary of Commerce notifies the President of adequate systems for processing and collecting tariff revenue.
- General Provisions:
- No Impairment of Authority: Clarifies that the order does not affect existing executive department authorities or the budgetary, administrative, or legislative roles of the Office of Management and Budget.
- Implementation Conditions: To be carried out in accordance with applicable law and subject to the availability of appropriations.
- No Legal Benefits: The order does not create enforceable rights or benefits for any party against the United States or its representatives.
- Date of Issuance: Signed on February 5, 2025, by the White House.
Risks & Considerations
- The amendment to the Executive Order regarding the synthetic opioid supply chain in China could impact international trade relations, potentially affecting research collaborations or partnerships that Vanderbilt University may have with Chinese institutions.
- The change in duty-free de minimis treatment could lead to increased costs for importing certain research materials or equipment from China, which may affect research budgets and timelines.
- There is a potential risk of increased administrative burden to ensure compliance with the new tariff regulations, which could require additional resources or adjustments in procurement processes.
- Vanderbilt University may need to monitor developments in trade policy closely to anticipate any further changes that could impact its operations or strategic initiatives.
Impacted Programs
- Vanderbilt’s Research Centers that rely on materials or collaborations with Chinese entities may need to reassess their supply chains and budget allocations to accommodate potential cost increases.
- The Office of Global Strategy might need to engage in strategic planning to mitigate any negative impacts on international partnerships and collaborations.
- Vanderbilt’s Procurement Office could play a crucial role in navigating the new tariff landscape, ensuring compliance, and optimizing procurement strategies to minimize financial impact.
Financial Impact
- The cessation of duty-free de minimis treatment could lead to increased costs for importing certain goods, potentially affecting research budgets and financial planning.
- Vanderbilt University may need to allocate additional resources to manage compliance with the new tariff regulations, which could impact overall financial strategies.
- There may be opportunities to explore alternative funding sources or partnerships to offset any increased costs associated with the new trade policies.
Relevance Score: 3 (The order presents moderate risks involving compliance and potential financial impacts.)
Key Actions
- Vanderbilt’s Center for Health Policy should monitor developments in the synthetic opioid supply chain regulations, particularly those involving trade with China. Understanding these changes can help the university align its research and policy recommendations with national efforts to combat opioid distribution.
- The Office of Federal Relations should engage with policymakers to understand the implications of the amended duties on synthetic opioids. This engagement can provide insights into potential funding opportunities for research initiatives aimed at addressing the opioid crisis.
- Vanderbilt’s Law School could explore the legal ramifications of the executive order, offering expertise on international trade law and its impact on public health policy. This could position the university as a thought leader in the intersection of trade and health law.
Opportunities
- The executive order presents an opportunity for Vanderbilt’s Medical Center to expand its research on opioid addiction treatment and prevention. By leveraging its expertise, the center can contribute to national efforts in reducing opioid-related harm.
- Vanderbilt can capitalize on the increased focus on synthetic opioid regulation by developing partnerships with government agencies and other institutions. These collaborations could lead to joint research projects and funding opportunities that enhance the university’s impact in public health.
Relevance Score: 3 (Some adjustments are needed to processes or procedures to align with national efforts in combating the opioid crisis.)
Timeline for Implementation
N/A – No specific deadline is provided; implementation is contingent on a condition (notification by the Secretary of Commerce) rather than a fixed timeframe.
Relevance Score: 1
Impacted Government Organizations
- Department of Commerce: The amendment directs the Secretary of Commerce to notify the President once adequate systems are in place to process and collect tariff revenue, directly impacting the department’s role in administering trade duties.
- Office of Management and Budget (OMB): The order explicitly states that it does not impair the functions of the OMB Director concerning budgetary, administrative, or legislative proposals, thus confirming the agency’s continued authority in these areas.
Relevance Score: 1 (Only 1 or 2 agencies are affected by the order.)
Responsible Officials
- Secretary of Commerce – Responsible for notifying the President once adequate systems are in place to fully and expediently process and collect tariff revenue for covered articles, as specified in the amendment.
Relevance Score: 4 (Directives affect an agency head, specifically the Secretary of Commerce, whose role is central to the implementation of the amendment.)
