Health Law Advisor

Many U.S. companies are responding to tariff pressures by rethinking supply lines. In a September 14, 2025, Wall Street Journal article, a major U.S. consumer goods manufacturer accused its competitors of dodging increased tariff costs by under-reporting the value of the goods imported into the United States. Such allegations are likely to incur scrutiny from the Department of Justice’s (DOJ’s) cross-agency Trade Fraud Task Force, which is aimed at investigating such allegations and prosecuting violations of law (see our September 5 blog post). 

In addition to consumer goods, this heightened scrutiny can also impact imported medical goods from everyday disposables to expensive imaging devices. Importers, manufacturers, and all parties involved in international supply chains, including end-users, should take notice: federal agencies and prosecutors have long used data mining to identify trends and to target investigations. Customs value data demonstrating the cost of imported goods is publicly available and can serve as an invaluable tool to help benchmark costs and conduct internal risk assessments.

This Alert explains: (a) what conduct may trigger liability; (b) how DOJ and other federal agencies use data mining to identify targets; (c) key statutes and penalties; (d) the implications of whistleblower complaints; and (e) steps companies should take to reduce risk.