Data & Methodology

Overview

RxTariff uses a combination of real-time government API data and a rules-based tariff classification engine to assign each drug to the appropriate Section 232 tariff tier. No data is purchased from third parties. All underlying information comes from publicly available, authoritative government sources.

Data Source 1: OpenFDA Drug Label API

When a user searches for a drug, we query the OpenFDA Drug Label API. This API provides: brand name, generic name, manufacturer name, product type (OTC vs. prescription), route of administration, and marketing status. The API covers over 150,000 drug products in the FDA database. We search by brand name first, then fall back to generic name if no brand match is found.

Limitation: The OpenFDA API does not directly report country of manufacture for most drugs. Country-of-manufacture data, when available, comes from our curated drug database.

Data Source 2: CMS NADAC Database

The National Average Drug Acquisition Cost (NADAC) is a weekly survey of retail community pharmacies conducted by the Centers for Medicare & Medicaid Services (CMS). It measures the average price pharmacies pay to purchase drugs from manufacturers or wholesalers. We query the most recent NADAC record for a given drug name, returning the per-unit acquisition cost and the classification (B = brand, G = generic). This classification is also used to help determine tariff status when OpenFDA data is incomplete.

Tariff Classification Logic

Each drug is classified using the following decision tree, applied in order:

1. Is it a generic or biosimilar? If NADAC classification = "G" or the product type contains "biosimilar" or "generic", classify as EXEMPT (0%).
2. Is it in a specialty exempt category? If the drug's therapeutic class matches orphan, nuclear, plasma-derived, fertility, cell/gene therapy, ADC, or CBRN categories, classify as SPECIALTY EXEMPT (0%).
3. Does the manufacturer have an MFN deal? Check manufacturer name against our curated list of 13 Annex III companies. If matched, classify as MFN DEAL (0%).
4. Country of manufacture? If the drug is manufactured in EU member states, Japan, South Korea, Switzerland, or Liechtenstein: 15%. If manufactured in the UK: 10%.
5. Default: If none of the above apply, classify as DEFAULT (100%).

Legal Source Documents

• White House Proclamation on Pharmaceutical Imports under Section 232 (April 2, 2026)
• Annex I — Tariff schedule and rates
• Annex II — Company-specific agreements
• Annex III — MFN deal companies (13 companies, effective July 31, 2026)
• Section 9903.04.60 through 9903.04.66 — HTSUS tariff codes for each tier

Known Limitations

• Country of manufacture: Not available via API for most drugs. Our curated database includes this where known, but many drugs default to the 100% tier due to insufficient country data.
• Real-time deal updates: New MFN company agreements may be announced at any time. We update our database as information is made public.
• NADAC coverage: Not all drugs have NADAC records, particularly very new drugs, specialty biologics, or drugs not widely dispensed in retail pharmacies.
• Insurance impact: We cannot calculate your specific insurance copay impact. We show acquisition cost changes, not final out-of-pocket costs.