US Pharmaceutical Facilities Under Construction and Tariff Implications

10/1/2025 Update: According to STAT, the administration confirmed the 100 % pharmaceutical tariffs did not take effect on Oct. 1; instead, it said it will “begin preparing” to impose them (timeline unspecified). STAT

On September 25, 2025, the Trump administration announced that, starting October 1, 2025, a 100% tariff will be applied to imported branded or patented pharmaceutical products. Companies currently building pharmaceutical manufacturing plants in the U.S.—either breaking ground or under construction—will be exempt from the tariff for products produced at these facilities. Generic or off-patent drugs are not affected.

For several years prior to the 2025 tariff announcement, pharmaceutical companies, both domestic and foreign, have been moving manufacturing capabilities to the United States. These investments have been driven by market advantages, long-term strategic considerations, and the desire to strengthen domestic production. The new tariff policy reinforces the importance of these moves, as companies with facilities already under construction are positioned to avoid the 100% tariff.

This exemption underscores the strategic importance of domestic manufacturing, a topic we explored in our previous post, Pharmaceutical Tariffs and Their Implications for the U.S. Market. That article outlined the administration’s rationale for tariffs: reshoring production to strengthen supply chains, reducing reliance on foreign countries, and stimulating domestic demand. It also highlighted the complexities of pharmaceutical supply chains, where tariffs are often applied at the point of “substantial transformation” of ingredients, a key factor in determining which products are impacted.

While exemptions are routinely occurring for various products related to tariffs and trade policy adjustments, it could be assumed that these organizations would not be subject to the incoming tariffs on October 1, 2025 given the construction status of their facilities. The Table below attempts to organize recent announcements from pharmaceutical companies, showing projects that are under construction or have already broken ground.

While many U.S.-headquartered pharmaceutical companies are building or expanding manufacturing facilities, several foreign-based firms are also investing heavily in domestic production. Companies such as Fujifilm Biotechnologies (Japan), Novo Nordisk (Denmark), Kyowa Kirin (Japan), Vetter (Germany), and Hikma Pharmaceuticals (UK) have broken ground or begun construction on U.S. facilities, which may ensure their other imported products will be exempt from the incoming 100% tariff.

These investments underscore a broader trend of reshoring pharmaceutical manufacturing to the U.S., driven not only by tariff incentives but also by the desire to strengthen supply chains, mitigate trade risks, and expand market presence. Both domestic and multinational companies are taking strategic steps to secure a foothold in U.S. production, reflecting the growing importance of onshore manufacturing in the pharmaceutical sector.

Note: The table is not an exhaustive list of all pharmaceutical manufacturing in the US. To create this table, we conducted a structured search of press releases and other sources to identify firms that have recently announced, planned, or begun construction on facilities. Organizations should be contacted directly for the most up-to-date information regarding their projects.

Non-U.S. organizations reported to be constructing manufacturing facilities in the United States and potentially exempt from the upcoming October 1st tariffs.

• Fujifilm Biotechnologies – Tokyo, Japan
• AstraZeneca – Cambridge, UK
• Roche – Basel, Switzerland
• Genentech / Roche – Basel, Switzerland (Genentech is US-based, Roche HQ in Switzerland)
• Novartis – Basel, Switzerland
• Sanofi – Paris, France
• Novo Nordisk – Bagsværd, Denmark
• GSK – Brentford, UK
• Kyowa Kirin – Tokyo, Japan
• Vetter – Ravensburg, Germany
• Hikma Pharmaceuticals – London, UK
• UCB – Brussels, Belgium

Given that many major pharmaceutical companies have already been expanding their U.S. manufacturing footprint in recent years, the impact of the tariff may be limited. In addition, several firms have reportedly been stockpiling surplus supply in anticipation of changes to tariff and trade policy. Market reaction also appeared muted, with no significant negative movement observed the day after the announcement.