US Medical Device Imports Teardown: Why Mexico — Not China — Is America's #1 Source
A data-driven teardown of US medical device imports using the CEPII BACI dataset, analyzing the difference between core devices and the PPE/consumables basket.
Sourcing Reality vs. Sourcing Rhetoric in MedTech
For MedTech supply-chain directors, commercial executives, and policy analysts, understanding where the United States gets its medical hardware is a critical part of risk management. Geopolitical tensions, Section 301 tariffs, and the Department of Commerce's Section 232 investigation into the security of the medical device supply chain have made sourcing a central boardroom issue. However, public discussions about US import reliance often run on a major misconception: that China is the primary exporter of medical devices to the United States. While China is a dominant supplier of personal protective equipment (PPE) and basic clinical consumables, the reality for actual medical hardware, diagnostic imaging, and orthopedic implants is completely different.
Scenario Question:
Where do America's medical devices actually come from, and how should that reshape our sourcing and tariff exposure planning?
Direct Answer:
The United States imported $71.2B in medical devices (defined under the WTO medical-equipment and orthopaedic HS codes, covering 57 distinct HS6 categories) in 2024, up from $64.5B in 2022. Mexico is the #1 source country, supplying $12.9B (18.1%) of these imports. Germany ranks second at $8.1B (11.3%), followed closely by China at $7.95B (11.2%), Ireland at $5.5B (7.8%), Singapore at $4.1B (5.8%), and Costa Rica at $4.0B (5.6%).
Across the broader 132-code medtech basket (which includes PPE, syringes, and clinical consumables), the US imported $133.1B in 2024. In this broader basket, China rises to #1 at $24.0B (18.0%), driven by its massive share of the PPE and low-cost consumables market, while Mexico drops to #2 at $21.5B (16.2%). For true medical devices, Mexico has remained the top US supplier throughout 2022–2024, while imports from China have flatlined.
This teardown provides a comprehensive, data-driven analysis of US medical device imports using the CEPII BACI bilateral trade database, explains why the country rankings flip when separating devices from consumables, trends sourcing shifts from 2022 to 2024, and analyzes the tariff risks associated with the ongoing Section 232 national security investigation.
How much does the US import in medical devices, and which country is #1?
To build an accurate picture of US imports, we analyzed product-level bilateral trade flows from the CEPII BACI HS22 database (covering the calendar years 2022 through 2024). We isolate "Core Medical Devices" by using the World Trade Organization (WTO) Medical Goods List, specifically filtering for Category B (Medical Equipment) and Category C (Orthopaedic Appliances). This "Device-Only" basket covers 57 distinct HS 6-digit product codes (such as electro-diagnostic apparatus, pacemakers, artificial joints, and diagnostic imaging hardware).
Using this device-only definition, US imports reached $71.2B in 2024, up from $64.5B in 2022, representing a two-year growth of 10.4%.
The table below ranks the top source countries supplying core medical devices (the 57-code WTO B+C basket) to the US in 2024, compared against their 2022 values:
| Rank | Country of Origin | 2022 Import Value | 2024 Import Value | 2024 Share (%) | Core Product Profile |
|---|---|---|---|---|---|
| 1 | Mexico | $10.6B | $12.9B | 18.1% | Catheters, surgical tubing, drapes |
| 2 | Germany | $7.7B | $8.1B | 11.3% | Imaging hardware, diagnostics |
| 3 | China | $8.5B | $8.0B | 11.2% | Patient monitors, low-cost electronics |
| 4 | Ireland | $5.1B | $5.5B | 7.8% | Cardiac stents, pacemakers, implants |
| 5 | Singapore | $3.8B | $4.1B | 5.8% | Micro-optics, pacemakers, hearing aids |
| 6 | Costa Rica | $3.4B | $4.0B | 5.6% | Infusion lines, medical assemblies |
| 7 | Switzerland | $3.0B | $3.1B | 4.4% | Precision implants, dental instruments |
| 8 | Japan | $2.2B | $2.5B | 3.4% | Flexible endoscopes, optical systems |
| 9 | Israel | $1.8B | $1.9B | 2.7% | Advanced laser optics, active implants |
| 10 | United Kingdom | $1.7B | $1.7B | 2.4% | Respiratory circuits, lab hardware |
Data Source: CEPII BACI HS22 Bilateral Trade Database (2022–2024), WTO Medical Goods List B & C categories.
Sourcing Saliency:
- Mexico as the MedTech Anchor: Mexico is the largest foreign supplier of medical devices to the US, sending over $12.9B in goods in 2024. This represents 18.1% of all device imports, driven by deep USMCA integration and massive assembly clusters in Tijuana and Ciudad Juárez.
- Germany and China Tied: Germany and China are effectively tied for second place, each holding roughly 11.3% and 11.2% of the device-only import market. However, their product mixes differ: Germany’s share focuses on high-value imaging systems (Siemens) and clinical capital equipment, while China’s share focuses on patient monitoring systems and active electronic components.
- The Sourcing Long Tail: Sourcing is highly distributed, with tax-optimized manufacturing hubs like Ireland and Costa Rica supplying a combined $9.5B (13.4%) of high-value implants and disposable assemblies.
Why does the ranking flip when you separate devices from PPE and consumables?
The most critical analytical distinction in medtech trade data is the difference between "Core Medical Devices" and the "Broad MedTech Basket." When a general market report declares that "China is America's largest source of medical imports," it is almost always lumping in textile-based PPE (masks, surgical gowns, protective suits) and low-value consumables (such as exam gloves and syringes) with high-value clinical hardware.
To illustrate this, we compared the 57-code Device-Only basket against the 132-code Broad MedTech Basket (which adds WTO Category A: Medicines/Consumables, Category D: PPE, and Category E: Other Medical Supplies):
Sourcing Rank Flipping: Device-Only vs. Broad MedTech Basket (2024)
| Rank | Country | Device-Only Imports (WTO B+C) | Share (%) | Broad Basket Imports (All 132 Codes) | Share (%) | Sourcing Profile |
|---|---|---|---|---|---|---|
| 1 | China | $7.95B | 11.16% | $23.95B | 18.00% | Dominant in PPE and cheap consumables |
| 2 | Mexico | $12.91B | 18.13% | $21.51B | 16.16% | Dominant in core hardware and drapes |
| 3 | Germany | $8.06B | 11.32% | $11.72B | 8.81% | Strong in capital imaging equipment |
| 4 | Ireland | $5.53B | 7.77% | $7.63B | 5.73% | High-value implants and cardios |
| 5 | Costa Rica | $4.02B | 5.64% | $6.91B | 5.19% | High-volume disposable assemblies |
1. The Broad Basket Sourcing Map ($133.1B Total)
Under the 132-code definition, US imports reached $133.1B in 2024.
- China rises to #1 with $23.95B (18.0%) of the total, driven by its dominance in textile PPE and rubber examination gloves.
- Mexico drops to #2 with $21.51B (16.2%).
- The imports are split across WTO categories: Medical Equipment ($54.6B), PPE ($32.9B), Other Supplies ($23.7B), and Orthopaedic ($16.6B).
2. The Device-Only Sourcing Map ($71.2B Total)
Once you strip out PPE, bandages, and basic consumables (Categories A, D, and E):
- Mexico rises to #1 with $12.91B (18.1%).
- Germany rises to #2 with $8.06B (11.3%).
- China falls to #3 with $7.95B (11.2%).
This flip occurs because China’s MedTech exports to the US are heavily weighted toward low-value, high-volume PPE and consumables. For healthcare supply chain directors, this means that while their PPE supply chains are heavily exposed to China, their actual clinical device hardware is anchored in North American nearshoring partners and Western Europe.
How Not to Be Misled by a Single "Medical Imports" Number
Because the ranking depends entirely on which HS codes you include, a defensible sourcing analysis should make its basket explicit. A useful decision rule:
- Name the basket before the number. If a figure does not state whether it covers device-only codes (e.g., WTO B+C / HS 9018–9022) or a broad basket that includes textile PPE and gloves, treat it as uncalibrated. The same country can be #1 or #3 depending on this single choice.
- Separate value from volume. China’s device share looks larger when measured by unit/line count (much of it low-value consumables) than by dollar value of clinical hardware. Tariff and shortage risk tracks value and criticality, not line count.
- Cross-check against a second source. Bilateral datasets (BACI, Comtrade) reconcile mirror flows differently than declared customs data (Census), so a 1–3 point country-share difference is normal; a rank swap (e.g., China ahead of Mexico for devices) is a red flag that the source is mixing in PPE.
This matters in practice because some trade-data vendor pages publish visibly incorrect country figures for US medical imports — typically by collapsing the broad basket into a single "medical" total and then ranking countries, which is exactly the conflation that pushes China to the top. The device-only ranking above (Mexico #1) is the one that matches OEC, Census HS 9018–9022, and BACI independently.
Key Sourcing Codes: Where Device and PPE Flows Concentrate
To show where the trade flows concentrate, the table below maps the HS 6-digit codes that drive each basket to their dominant sourcing patterns. (The WTO B+C device basket is an HS-level approximation of "medical devices"; individual code-level dollar values vary by database vintage and are not the basis of the country rankings above, which are computed across the full 57-code set.)
| HS6 Code | Description | Basket | Dominant Sourcing Pattern |
|---|---|---|---|
| HS 9018 | Medical, surgical, dental, or veterinary instruments and appliances | Core Device | The largest device code group; OEC reports roughly $41B in US "Medical Instruments" imports for 2024, led by Mexico, then Costa Rica and Germany |
| HS 9021 | Orthopaedic appliances, artificial joints, hearing aids, pacemakers | Core Device | Concentrated in Ireland (Galway/Cork cardiovascular and orthopaedic clusters) and Singapore |
| HS 9022 | X-ray, alpha/beta/gamma radiation apparatus for medical use | Core Device | Capital imaging concentrated in Germany and Japan |
| HS 6307 | Made-up textile articles (incl. non-woven face masks, surgical gowns) | Broad PPE | Dominated by China on textile PPE — the code that pulls China to #1 in the broad basket |
| HS 4015 | Rubber gloves (incl. examination gloves) | Broad Consumables | Dominated by Malaysia and China |
| HS 9018 (syringes/needles/catheters subcodes) | Disposable sterile assemblies | Broad Consumables | High-volume assembly in Mexico and Costa Rica |
Code Sourcing Dynamics:
- HS 9018 (Medical Instruments): This is the anchor code of the device basket — the single largest line in US device imports. Mexico is the leading assembly point for high-volume sterile components, while Germany supplies premium optics, sensors, and capital imaging. OEC independently corroborates Mexico as the top US origin for this category (roughly $12–13B in recent years).
- HS 9021 (Orthopaedic and Implant Appliances): This high-value category is led by Ireland's MedTech clusters in Galway and Cork, where corporate tax rates and technical specialization support cardiovascular and orthopaedic manufacturing, with Singapore a secondary hub.
- HS 6307 (Textile PPE): The largest weight in the broad basket that is not a device. China's dominance of non-woven face masks and gowns is precisely why China rises to #1 once PPE is included — yet this category has minimal carryover into core diagnostic and interventional hardware.
How did US device sourcing shift between 2022 and 2024?
The period between 2022 and 2024 saw significant shifts in US medical device sourcing, driven by voluntary "China+1" diversification strategies and Section 301 tariff pressures.
The table below trends imports from the top three sourcing destinations for core medical devices (WTO B+C) over this three-year period:
| Country | 2022 Imports | 2023 Imports | 2024 Imports | Three-Year Trend |
|---|---|---|---|---|
| Mexico | $10.6B | $13.1B | $12.9B | +22% overall increase |
| Germany | $7.7B | $7.9B | $8.1B | +5% steady growth |
| China | $8.5B | $7.5B | $8.0B | ~-6% net contraction |
Sourcing Shift Analysis:
- The Mexico Surge: Imports from Mexico grew by 22.1% between 2022 and 2024, rising from $10.6B to $12.9B. This highlights the rapid expansion of border manufacturing facilities to support nearshoring initiatives.
- China's Pullback and Rebound: Sourcing from China contracted by 12.8% in 2023 as manufacturers diversified their component supply lines. While imports from China rebounded slightly in 2024 to $7.95B, they remained below their 2022 baseline, reflecting a structural shift rather than a temporary trend.
- Germany's Stability: Sourcing from Germany grew at a steady 5.4%, reflecting the stable demand for high-end diagnostic and therapeutic imaging systems.
Which device categories and nearshoring hubs drive the Mexico/Costa Rica surge?
The nearshoring movement is concentrated in two primary regional hubs: the USMCA border zone in Mexico and the CAFTA-DR free trade zones in Costa Rica. These hubs specialize in distinct product categories, creating complementary manufacturing footprints.
1. Mexico: The High-Volume Assembly Anchor
- Primary Hubs: Ciudad Juárez (Chihuahua) and Tijuana (Baja California).
- Regional Differences within Mexico: Sourcing profiles vary by location. The northern border zones (Tijuana, Juárez, Mexicali) specialize in high-volume sterile assembly and packaging due to direct road connections. The central Bajío region (Querétaro, Jalisco, Guadalajara) is emerging as a higher-tech hub, focusing on active medical electronics, custom PCBA component assembly, and metal mold manufacturing.
- Key Specialties: High-volume sterile assembly, IV administration sets, surgical tubing, syringes, and custom surgical drapes.
- Driver: Direct road freight connections to US distribution hubs, allowing for logistics lead times of 2 to 5 days via USMCA-compliant customs channels.
2. Costa Rica: The Precision Micro-Components Leader
- Primary Hub: Coyol Free Zone (Alajuela).
- Key Specialties: Catheters, guide wires, micro-valves, endoscopy components, and complex disposable delivery systems.
- Driver: Tax-free operations within free trade zones, a highly educated local engineering workforce, and direct air freight connections to US device packaging plants. Imports from Costa Rica rose from $3.4B in 2022 to $4.0B in 2024, a 17.5% increase.
What does this mean for tariff exposure and Section 232 risk?
The concentration of US medical device imports in Mexico, Germany, Ireland, and Singapore has significant implications for trade policy and risk management. On September 24, 2025, the US Department of Commerce announced a formal Section 232 national security investigation to evaluate whether the level of medical device imports impairs national security by threatening domestic production capacity.
The investigation was initiated on September 2, 2025, with the public comment notice published in the Federal Register on September 26, 2025; under Section 232 of the Trade Expansion Act of 1962, Commerce has up to 270 days to report to the President. For the full statutory timeline and the deficit context driving the probe, see our US medical device import dependence analysis, which covers the Section 232 process in depth.
Sourcing Risk Splits into Two Distinct Profiles
The device-vs-PPE split in this teardown is what makes Section 232 exposure assessment tractable. Because the United States is highly import-dependent — estimates of the import share of medical devices used domestically range from roughly one-third (FDA, 2019 fact sheet) to about two-thirds under broader medtech-basket definitions (UNC CBOH tariff brief, 2025) — any broad action could disrupt clinical operations, but the exposure concentrates very differently by category:
- The China Tariff Scenario (High-Risk PPE): China's device-only share is only ~11%, but it dominates the broad basket on low-margin, high-volume consumables (syringes, gowns, examination gloves, textile PPE). Tariff pressure on China therefore lands hardest on PPE and disposables, not on imaging or implants. Sourcing teams should accelerate transitions to alternative suppliers in Southeast Asia (Malaysia, Thailand) or Latin America for these lines.
- The Allied Sourcing Profile (Low-Risk Hardware): For actual medical hardware, the bulk of imports originate in USMCA partners (Mexico) or friendly nations (Germany, Ireland, Singapore). Sourcing teams should focus on verifying that their Mexican assemblies comply with USMCA rules of origin (ensuring regional value content meets the required thresholds) to maintain tariff-exempt status.
The policy implication is the same one this teardown makes for commercial teams: a single "where do our devices come from" number obscures two very different risk profiles, and any Section 232 remedy that treats PPE and capital hardware identically will misprice the actual exposure.
How This BACI Teardown Differs From a Census Trade-Deficit View
Readers who have seen our US medical device import dependence analysis will notice the 2024 country figures here do not match that piece line-for-line. That is expected, not a contradiction — the two analyses answer different questions with different scopes and data sources:
| Dimension | This teardown (device-vs-PPE ranking) | Import-dependence analysis (trade deficit) |
|---|---|---|
| Primary data source | CEPII BACI HS22 bilateral trade (product-level) | US Census Bureau customs data |
| Product scope | WTO Medical Goods List: 57 HS6 "device-only" codes (Category B + C) vs a 132-code broad basket | Five HS4 core-device codes: HS 9018–9022 |
| Question answered | Which country is #1 for devices, and why does China only lead when PPE is included? | How big is the core-device trade deficit, and how has it trended since 2013? |
| Why Mexico's 2024 share differs | BACI reconciles mirror flows and uses the narrower 57-code device set, so Mexico lands at ~$12.9B (18%) | Census reports declared customs value across 9018–9022, where Mexico is ~$14.8B (21%) |
Two consequences flow from this. First, no single "US medical device imports" number is canonical — the device-only BACI basket ($71B) and the Census 9018–9022 total ($70B) land in the same neighborhood for 2024, while OEC's HS4-9018-only figure (~$41B) is deliberately narrower still. Second, the ranking conclusion is robust across all three: Mexico is the #1 US source for actual medical devices, and China only moves up the list once PPE and consumables are folded in. The device-vs-PPE distinction is the contribution this teardown adds on top of the deficit work.
Basket Definitions in Plain Terms
- Device-only (WTO B + C, 57 HS6 codes): electro-diagnostic apparatus, imaging hardware, syringes and catheters, orthopaedic implants, hearing aids, pacemakers, and dental/ophthalmic instruments — the things a clinician would recognize as a "device."
- Broad basket (132 codes): the device-only set plus textile PPE (masks, gowns), rubber gloves, bandages, reagents, and other consumables. This is the basket general market reports use when they say "medical imports," and it is where China's PPE volume pushes it to #1.
- Why the split matters for sourcing teams: a device manufacturer's tariff and single-source exposure looks like the device-only column (Mexico, Germany, Ireland, Singapore); a hospital PPE buyer's exposure looks like the broad column (China, Malaysia). Conflating the two is the most common error in medtech trade commentary.
Frequently Asked Questions
Is China the largest source of US medical device imports?
No. China is the largest exporter of the broad medtech basket (totaling $24.0B in 2024), which includes PPE, bandages, and basic consumables. However, for actual medical hardware and devices (WTO B+C categories), Mexico is the top supplier at $12.9B, with Germany and China roughly tied for second place at ~$8.0B.
Why is Mexico the top device supplier to the US?
Mexico’s top position is driven by its close geographic proximity, direct road freight logistics (2-5 days lead time), lower labor costs, and the tariff-free provisions of the USMCA framework. This integration has led major MedTech companies to build massive maquiladora assembly plants in Tijuana and Ciudad Juárez.
How much of US medical device supply is imported versus domestically produced?
Estimates vary with methodology and year. The FDA's 2019 fact sheet put the import share at roughly one-third of devices used in the US, while broader medtech-basket analyses (such as the UNC CBOH 2025 tariff brief) place it closer to two-thirds. Either way, sourcing is heavily globalized, with foreign manufacturing sites providing both completed devices and critical sub-components used in US assembly plants.
Sourcing Recommendations for MedTech Leaders
To mitigate these tariff and supply chain risks, manufacturers should transition from single-source manufacturing. Implementing a dual-sourcing model requires:
- Supplier Qualification: Audit secondary supplier facilities under ISO 13485.
- Sterilization Validation: Perform sterilization validation studies (such as EO sterilization under ISO 11135 or radiation under ISO 11137) at the secondary site.
- FDA Submissions: Submit a 510(k) change supplement or a 30-Day Notice for Class II or Class III devices before marketing products manufactured at the new site.
For broader policy context, see our medical device tariffs and trade-war impact and medical device nearshoring and reshoring strategy. To review the historical trade deficit trends, refer to our US medical device import dependence. For details on the demand side of the US market, see the US federal medical device procurement teardown.
Disclaimer: This analysis is based on bilateral trade data from the CEPII BACI HS22 database (2022–2024). Sourcing and regulatory compliance involve legal and operational risks. Manufacturers should consult with qualified supply chain, trade, and legal advisors before making strategic restructuring decisions.