Modifying Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China
11/4/2025
Action Summary
- Background and Context: Revises previous orders addressing the synthetic opioid supply chain from the People’s Republic of China, citing national security, foreign policy, and economic threats linked to fentanyl and related chemicals.
- Duty Modification: Reduces the additional ad valorem duty from 20% to 10% on specific articles from China, effective November 10, 2025, in recognition of the PRC’s commitment to halt the problematic chemical exports.
- Implementation Details:
- Modifies heading 9903.01.24 and related HTSUS notes to reflect the new 10% duty.
- The Secretary of Homeland Security, in consultation with the U.S. International Trade Commission, will determine if further modifications are needed via a Federal Register notice.
- Monitoring and Recommendations:
- The Secretary of Homeland Security, with input from State, Treasury, and other officials, will monitor the status of the PRC’s implementation of its commitments.
- Updates and recommendations will be provided to the President, with potential adjustments to the order if commitments are not met.
- Delegation of Authority: Empowers the Secretary of Homeland Security to adopt rules, regulations, or guidance as necessary, with full authority to redelegate within the department.
- General Provisions:
- Confirms that the order does not impair existing legal authorities or create enforceable rights for third parties.
- Includes severability provisions and stipulates that publication costs will be borne by the Department of Homeland Security.
Risks & Considerations
- The Executive Order aims to address the synthetic opioid supply chain from China, which is a critical public health issue. However, any changes in trade duties and international relations could have broader economic implications, potentially affecting the cost of goods and services.
- The reduction in duties from 20% to 10% suggests a tentative improvement in U.S.-China relations concerning the opioid crisis, but it also signals ongoing monitoring and potential for further modifications. This creates an environment of uncertainty that could affect international collaborations and research funding related to public health and trade.
- Any failure by the PRC to adhere to its commitments could lead to increased duties or sanctions, impacting economic stability and international partnerships, which are important for university research collaborations.
- Vanderbilt University may need to consider how these geopolitical dynamics affect its research funding, particularly in fields related to international trade, law, and public health policy.
Impacted Programs
- Vanderbilt Law School might see increased demand for expertise in international trade law and policy, given the Executive Order’s implications for U.S.-China trade relations.
- Vanderbilt University Medical Center could be involved in monitoring and researching the public health impacts of synthetic opioids, with potential for increased funding for such initiatives.
- The Center for Health Policy at Vanderbilt might engage in policy analysis and research concerning the effects of changing trade policies on public health and safety.
- Programs focusing on international relations and economics may need to adapt their curricula to address the evolving trade dynamics and their implications on global health and security.
Financial Impact
- The reduction in duties might stabilize some aspects of trade costs, which could indirectly affect research budgets and funding allocations within the university, particularly in fields related to international economics and trade.
- While there is a potential for positive financial impacts through improved trade relations, the uncertainty and potential for future changes pose a risk that could affect financial planning and resource allocation.
- Opportunities may arise for securing federal funding related to research on the opioid crisis and international trade compliance, which could benefit university initiatives in these areas.
- Changes in international trade dynamics and their economic impacts may influence the university’s strategic partnerships and global engagement efforts.
Relevance Score: 3 (The order involves moderate risks and requires ongoing monitoring of compliance and international trade dynamics.)
Key Actions
- Vanderbilt’s Center for Research Development should explore opportunities for research grants related to national security and economic impacts of synthetic opioid trade regulations. This could enhance the university’s research portfolio in public policy and international trade.
- The Department of Political Science should analyze the geopolitical implications of the U.S.-China trade dynamics, focusing on synthetic opioids. This research can contribute to academic discourse and provide insights into international relations and policy-making processes.
- Vanderbilt’s Public Policy Studies Program could offer specialized courses or workshops on the intersection of international trade laws and public health crises. This would prepare students for careers in policy-making and international relations.
- The Office of Federal Relations should monitor changes in international trade law and their potential impacts on university operations and funding. Engaging with policymakers could also help align university interests with federal priorities.
Opportunities
- The executive order offers an opportunity for Vanderbilt’s School of Medicine to lead in research on opioid mitigation strategies, particularly in collaboration with government agencies aiming to address the synthetic opioid crisis.
- By focusing on the implications of changes in tariffs and trade policy, Vanderbilt can position itself as a thought leader through seminars and policy briefings that engage with both academic and government stakeholders.
Relevance Score: 3 (Adjustments may be needed to align research and policy focus with new federal priorities regarding trade and public health.)
Timeline for Implementation
Effective November 10, 2025 at 12:01 a.m. EST for goods entered for consumption or withdrawn from the warehouse for consumption.
This timeline was determined from Section 2(a) which explicitly states the new duty modifications take effect on November 10, 2025.
Relevance Score: 5
Impacted Government Organizations
- Department of Homeland Security (DHS): Responsible for modifying the Harmonized Tariff Schedule, monitoring the national emergency conditions, and coordinating related actions in consultation with other agencies.
- U.S. International Trade Commission (USITC): Consulted by DHS to determine and implement any additional modifications to the Harmonized Tariff Schedule of the United States (HTSUS).
- Department of State: Involved in monitoring the PRC’s commitments and coordinating with DHS to address the national emergency and provide updates to the President.
- Department of the Treasury: Consulted by DHS during monitoring and recommendations related to the national emergency, ensuring financial and economic considerations are integrated.
- Department of Justice (DOJ) – Attorney General: Engaged in monitoring and coordinating with DHS and the State Department regarding further actions if conditions warrant additional measures.
- Office of Management and Budget (OMB): Its functions in budgetary, administrative, or legislative proposals are acknowledged, ensuring that actions under the order are implemented with financial oversight.
Relevance Score: 3 (A moderate number of Federal Agencies are impacted by the executive order.)
Responsible Officials
- Secretary of Homeland Security – Charged with modifying the HTSUS via necessary regulatory changes, coordinating with other officials, and monitoring the conditions underlying the national emergency.
- United States International Trade Commission – Consulted by the Secretary of Homeland Security to determine any additional modifications to the Harmonized Tariff Schedule.
- Secretary of State – Consulted for monitoring the conditions related to the PRC’s commitments and national security implications.
- Secretary of the Treasury – Consulted in monitoring the economic aspects of the national emergency and the impact of the duty modifications.
- Attorney General – Consulted for policy recommendations and to inform on circumstances affecting further action.
- Assistant to the President for National Security Affairs – Consulted on issues impacting national security as part of the monitoring and recommendation process.
- Assistant to the President for Homeland Security – Consulted on homeland security matters to support the implementation and monitoring of the order’s directives.
Relevance Score: 5 (Directives affect top Cabinet officials and high-level agency heads with substantial national security, trade, and economic implications.)