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Commission In Limbo: SCOTUS Puts CPSC Commissioners Back Out of Action

Client Alert | 1 min read | 07.24.25

In May 2025, the Trump Administration, asserting Executive authority, terminated the three Democratic Commissioners of the Consumer Product Safety Commission. On June 13, 2025, a Maryland district court aborted the without-cause termination while a legal challenge proceeds, leaving the Commissioners in place.

No longer. On July 23, 2025, the Supreme Court granted an emergency request and stayed the district court’s blocking order. The six-Justice majority reasoned that the harm to the government from the stay order outweighs a Commissioner’s inability to perform his or her statutory duty.

While the majority ruling was unsigned, three Justices by name dissented, declaring this an unwarranted use of the Court’s stay authority.

Crowell will be monitoring developments as they unfold. 

Insights

Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....