Beware Of GSA's Price Reductions Clause

The California Office of Environmental Health Hazard Assessment recently amended its regulations concerning requirements for consumer product warnings to qualify for “safe harbor” protection from enforcement actions brought under the Safe Drinking Water and Toxic Enforcement Act of 1986, commonly known as Proposition 65.

As detailed in Part I of our three-part series on Minimizing Customs Enforcement and False Claims Act Risks, the combination of the new high-tariff environment, the heightened ability of Customs (and the general public) to data mine, and the Department of Justice’s stated focus on using the False Claims Act substantially increases import-related risks.

Foley partner Kyle Faget, co-chair of the firm’s Medical Devices Area of Focus, is speaking in American Conference Institute’s Inaugural Summit on GLP-1 Law & Policy on July 24.