Tariff relief for Swiss-origin generic drugs: What importers need to know

ARTICLE | December 22, 2025

Authored by RSM US LLP

Swiss-origin generic pharmaceuticals: What has changed

Earlier in 2025, the United States imposed reciprocal tariffs on certain Swiss-origin goods, including generic pharmaceuticals, as part of ongoing trade negotiations. However, the U.S. government on Dec. 18, 2025, published a Federal Register notice announcing the removal of reciprocal tariffs on Swiss-origin generic pharmaceuticals and their ingredients, effective retroactively to Nov. 14, 2025. This development stems from a new trade agreement with Switzerland and Liechtenstein aimed at fair and balanced trade and ensuring continued access to critical medical supplies.

Importers who paid duties on covered products since Nov. 14, 2025, may qualify for refunds. The tariff relief applies specifically to generic pharmaceuticals and their ingredients manufactured in Switzerland.

The removal of these tariffs may reduce costs for pharmaceutical importers and distributors, potentially helping them maintain supply chain stability and profitability. Importers should review their records promptly to identify eligible entries and prepare documentation to support refund claims.

For companies with global operations, this change also intersects with transfer pricing and customs valuation, making proactive planning critical.

What importers can do to try to secure refunds

To take advantage of this tariff relief, importers should review their entries and prepare the documentation needed to support refund claims. Consider taking the following steps:

1. Identify eligible entries: Review import records to identify entries of Swiss-origin generic pharmaceuticals and ingredients imported on or after Nov. 14, 2025, that were subject to the reciprocal tariff.
2. Prepare documentation: Gather supporting documentation, including commercial invoices, bills of lading, entry summaries, and proof of Swiss origin and product classification as a generic pharmaceutical or ingredient.
3. Coordinate with customs brokers to file refund claims: Work with your customs broker to prepare and submit post-summary corrections (PSCs) to U.S. Customs and Border Protection (CBP), clearly referencing the Federal Register notice and providing all required documentation to substantiate the claim for tariff relief.
4. Monitor refund processing: Track the status of refund claims and maintain communication with your customs broker and CBP to ensure timely processing and resolution.

Transfer pricing and customs valuation

If your company’s transfer pricing policy was affected by the tariffs, ensure that any adjustments to intercompany pricing are reflected in both your customs and tax filings.

CBP allows for retroactive adjustments to customs value if an objective formula was in place prior to importation and the adjustment mechanism existed at the time of entry.

Proper documentation and alignment with section 482 transfer pricing policies are critical for compliance and refund eligibility.

Coordination with tax and trade advisors

Given the interplay between customs, tax, and transfer pricing, consult with your tax and trade advisor to ensure all aspects of the refund process are addressed and to mitigate any potential compliance risks. Prompt action is required to identify eligible entries, prepare documentation, and coordinate with customs brokers for timely refund claims.

Please connect with your advisor if you have any questions about this article.

This article was written by Mark Ludwig, Jodi Ader and originally appeared on 2025-12-22. Reprinted with permission from RSM US LLP.
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