Rendering of Eli Lilly’s $6.5 billion pharmaceutical manufacturing campus at Generation Park in Houston, Texas.
Views from pharma execs
- J&J’s Duato: tariffs “can create disruptions in the supply chain, leading to shortages” and tax policy is a better tool to grow U.S. capacity. Healthcare Brew
- AstraZeneca’s chair: “medicines should be exempted from any kind of tariffs” because they harm patients and restrict health equity. Bloomberg
- Policy backdrop: Commerce launched a Section 232 investigation into pharmaceutical imports in April, setting the stage for potential trade actions. Federal Register
- Cost signals: J&J estimated $400M in 2025 existing tariff-related costs (metals/China duties) earlier this year. Healthcare Brew.
There is not a ton of clarity on the 100% tariffs President Trump threatened to impose on pharmaceutical imports beginning October 1. As of now, the tariffs appear to be in limbo, with the White House pausing implementation while it seeks price and investment commitments from industry. Pfizer, for one, secured a separate, three-year tariff exemption via a pricing and U.S.-investment deal.
Commerce Secretary Howard Lutnick said during the Pfizer announcement that the administration was “going to let [the talks] play out and finish these negotiations, because they are the most important thing to the American people,” according to Politico.
With tariffs potentially looming, drugmakers and investors are probing what triple-digit import taxes would mean—and who might be exempt if they were enacted. The administration’s proposed working definition for exemption is simple: a company is “building” if a U.S. plant has broken ground or is under construction.
What counts as “building”? A Trump Truth Social post announcing the plan defined it as “breaking ground” or “under construction.” R&D sites, packaging facilities, retrofits and CDMO arrangements remain gray areas until formal customs guidance lands. Items in the middle include announced facilities where construction hasn’t yet started and sites focused primarily on R&D, packaging or CDMO capacity.
| Company | Project / Facility Focus | Location | Investment ($M USD) | Status (Key Date) | Tariff Exemption Likely? |
|---|---|---|---|---|---|
| Lilly | LEAP LP1 API Campus (Manufacturing (API)) |
Lebanon, IN | 4,500 | Under construction (2023–2025) | Yes |
| Lilly | Lilly Medicine Foundry (R&D + Advanced Manufacturing) |
Lebanon, IN | 2,000 | Ground broke (May 6, 2025) | Yes |
| Merck | Wilmington Biologics Center (Biologics Manufacturing) |
Wilmington, DE | 1,000 | Ground broke (Apr 29, 2025) | Yes |
| J&J | Wilson Biologics Manufacturing Campus (Biologics Manufacturing) |
Wilson, NC | 2,000 | Ground broke (Mar 21, 2025) | Yes |
| Novo Nordisk | Clayton Fill-Finish Expansion ($4.1B) (Fill-Finish Manufacturing) |
Clayton, NC | 4,100 | Under construction (Jun 2024–) | Yes |
| AbbVie | North Chicago API Facility ($195M) (Manufacturing (API)) |
North Chicago, IL | 195 | Ground broke (Sep 29, 2025) | Yes |
| Gilead | NTDC – Technical Development & Manufacturing Hub (Development & Manufacturing) |
Foster City, CA | 300 | Ground broke (Sep 3, 2025) | Yes |
| GSK | Marietta Site Expansion (Vaccines & Drug Substance) |
Marietta, PA | 800 | Construction underway (Late 2024–) | Yes |
| Novartis | Indianapolis RLT Manufacturing Facility (Radioligand Therapy (RLT)) |
Indianapolis, IN | 300 | Operational / Expansion broke ground (Sep 4, 2024) | Yes |
| Amgen | Holly Springs Drug Substance Plant + Expansion (Biologics Manufacturing) |
Apex, NC | 1,500 | Operational / Expansion under construction (2025–) | Yes |
| Roche | Holly Springs Manufacturing Facility ($700M) (Biologics/Metabolic Medicines Manufacturing) |
Apex, NC | 700 | Ground broke (Aug 25, 2025) | Yes |
| Vertex | Leiden Center II / Jeffrey Leiden Center (R&D + Clinical Manufacturing) |
Boston, MA | 300 | Operational / Expansion underway (2024–2026) | Yes |
| BMS | Devens Cell Therapy Facility (Cell Therapy Manufacturing) |
Devens, MA | 300 | Operational (Jun 2023 FDA approval) | No† |
| Moderna | Marlborough mRNA Manufacturing Center (Manufacturing + Offices) |
Marlborough, MA | 322 | Fit-out/Expansion (2023–2025) | Maybe* |
| FUJIFILM | Holly Springs Biologics CDMO Campus (Biologics Manufacturing (CDMO)) |
Holly Springs, NC | 3,200 | Operational (Phase 1) (Sep 24, 2025) | Yes |
| Nusano | Radioisotope Production Facility (Radiopharmaceutical Manufacturing) |
West Valley City, UT | 300 | Operational (Aug 21, 2025) | Yes |
| Biocon Ltd. | OSD Manufacturing Facility (Manufacturing (Generics / OSD)) |
Cranbury, NJ | 30 | Operational / Inaugurated (Sep 10, 2025) | Yes |
| Regeneron | Tarrytown HQ Campus Expansion (R&D + Manufacturing) |
Tarrytown, NY | 3,600 | Underway (2025–) | Maybe |
| Amgen | New Albany Final Product Facility + Expansion (Final Product / Packaging) |
New Albany, OH | 1,400 | Operating / Expansion announced (Apr 25, 2025) | Maybe |
| Bayer | Myerstown Packaging Expansion (Consumer Health Manufacturing/Packaging) |
Myerstown, PA | 44 | Opened (Apr 16, 2025) | Maybe |
| Takeda | Los Angeles Plasma Fractionation Expansion (Plasma-Derived Therapies Manufacturing) |
Los Angeles, CA | 230 | Announced/Underway (Jun 11, 2024) | Maybe |
| J&J | Dedicated biologics suite @ FUJIFILM (Biologics Manufacturing (CDMO)) |
Holly Springs, NC | 2,000 | Announced / Upcoming (Aug 21, 2025) | Maybe |
| Lilly | Generation Park API Manufacturing Facility ($6.5B, 1M sq ft) (Manufacturing (Small-molecule API)) |
Houston, TX | 6,500 | Announced / Planned (Sep 23, 2025) | Maybe |
| Lilly | West Creek Business Park Integrated API + Drug Product Facility ($5B) (Manufacturing (Biologics/ADC & API)) |
Goochland County, VA | 5,000 | Announced / Planned (Sep 16, 2025) | Maybe |
| AstraZeneca | Virginia Drug Substance Manufacturing Center ($4B) (Manufacturing (Drug Substance)) |
Albemarle County, VA | 4,000 | Announced (Jul 2025) | Maybe |
| Gilead | R&D Building (190k sf) (R&D) |
Foster City, CA | 250 | Under construction (2024–2025) | No |
| Sanofi | Morristown Flagship U.S. Office (M Station West) (Office (HQ/US)) |
Morristown, NJ | 130 | Opened (May 22, 2025) | No |
| Amgen | Science & Innovation Center ($600M) (R&D / Innovation) |
Thousand Oaks, CA | 600 | Announced (Sep 2, 2025) | No |
* Moderna footnote: litigation over the Marlborough build-out in April 2025 suggests construction was not finalized; without clear evidence it continued past Oct. 1, “Maybe” reflects the construction-based exemption threshold.
Sources: WBJ; Bisnow (Apr 18, 2025).
