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FDA Presses Pause on Domestic and Foreign Inspections for all FDA-Regulated Products Due To COVID-19 Concerns

Client Alert | 1 min read | 03.20.20

In response to the recent COVID-19 pandemic, the U.S. Food and Drug Administration (“FDA”) has temporarily paused all domestic and international on-site inspections not deemed “mission-critical.”

On Wednesday, March 18th, FDA Commissioner Stephen Hahn announced that the Agency would temporarily halt domestic inspections not deemed “mission-critical,” citing concerns for the health and well-being of its staff.  These are inspections the FDA conducts every few years based on a risk analysis. Instead, during this interim period, the Agency will evaluate alternative ways to conduct inspectional work to ensure the safety of the firm and the FDA staff such as evaluating records in lieu of conducting onsite inspections.  It is important to note that domestic for-cause inspections will proceed if considered “mission-critical.”

Similarly, on March 10th, the Agency announced that it would temporarily scale back foreign inspections, through April, not deemed “mission-critical.”  The FDA cited a number of factors including State Department travel advisories, CDC travel recommendations, and other guidance.  FDA stated that in the interim, it would employ additional tools to ensure the safety of imported products, including denying entry of unsafe products, physical inspection, product sampling at the border, and reviewing the manufacturer’s compliance history, among others.  As is the case with domestic inspections, inspections of foreign facilities deemed “mission critical” will continue on a case-by-case basis.

FDA encourages the industry to “own” safety and quality during this unprecedented time, and adhere to existing reporting and cGMP requirements pertaining to manufacturing, sanitation, and process controls. 

In short, the spring on-site inspection that your business has been expecting probably won’t happen.  Domestic and foreign manufacturers, nonetheless, should continue adhering to all cGMP and reporting requirements, as FDA indicated it may rely on such reports to determine manufacturer compliance.  In addition, we expect that the FDA will extend its suspension of non-critical foreign inspections beyond April.

Insights

Client Alert | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....