Insights

Washington – April 30, 2026: Crowell & Moring hosted its 27th annual George Bailey Public Service Awards ceremony this month, named after the hero of the classic movie, "It's a Wonderful Life." The awards recognize the firm's lawyers and staff who have made a substantial impact on the lives of others through their pro bono efforts. 

Washington – January 2, 2020: Crowell & Moring elected eight lawyers to the firm’s partnership, effective January 1, 2020. The firm also promoted seven attorneys to the position of senior counsel, and 26 associates to the position of counsel. The new partners have been promoted from within the ranks of the firm’s Washington, Los Angeles, and San Francisco offices. The new partners have been promoted from across offices and practice groups, including White Collar & Regulatory Enforcement, Health Care, International Trade, Intellectual Property, Privacy & Cybersecurity, Government Contracts, Litigation, and Antitrust.

On April 2, 2026, President Trump issued a Proclamation invoking Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. § 1862), to impose tariffs on imports of patented pharmaceuticals, biologics, and associated ingredients into the United States.  The action affects pharmaceutical manufacturers, importers, and supply chain participants.   

EDIT The U.S. Food and Drug Administration (FDA) walked back its policy that allowed COVID-19 antibody test kits to enter the market without agency review. In its original March 16 Final Guidance, FDA allowed commercial manufacturers to market and sell antibody test kits after internally validating their own products and notifying FDA. The Agency did not require emergency use authorization (EUA) as it did with PCR (molecular) testing, though seeking an EUA was “encouraged.”

In this issue:

During these difficult times global businesses must streamline and protect their supply chain operations, manage new sourcing, navigate border issues, keep abreast of rapidly changing regulations, and deal with contract disputes. Importers and other businesses in the supply chain who take key steps now may mitigate potential losses while ensuring compliant and efficient supply chains. Topics to be discussed include:

Join the Crowell & Moring trade team for a 30-minute update on the U.S.-China trade negotiations, the imposition of tariffs, and the continued escalation of tensions from the White House. Hear the latest on President Trump’s potential next steps, the status of the product exclusion process for Lists 1, 2, and 3, and how to respond to the recent announcement of List 4, covering virtually all the remaining U.S. imports from China.

On April 2, 2026, President Trump signed two presidential proclamations invoking Section 232 of the Trade Expansion Act of 1962 and Section 604 of the Trade Act of 1974 to impose significant new tariffs on imports of patented pharmaceuticals and pharmaceutical ingredients, and to restructure the existing tariff regime for aluminum, steel, and copper articles and their derivatives. The pharmaceutical proclamation targets patented drugs and active pharmaceutical ingredients (APIs), citing the Secretary of Commerce’s finding that approximately 53 percent of patented pharmaceutical products distributed domestically are produced outside the country, and only 15 percent of patented APIs by volume are domestically produced for the U.S. market. The metals proclamation amends three prior Section 232 actions — Proclamation 9704 of March 8, 2018 (aluminum), Proclamation 9705 of March 8, 2018 (steel), and Proclamation 10962 of July 30, 2025 (copper) — to restructure how tariffs are calculated and which derivative articles are covered.  The administration also issued two separate fact sheets for these actions.

Key Takeaway: U.S. Customs and Border Protection (“CBP”) is considering amending its regulations to require new disclosures designed to give the agency greater visibility into the supply chains of goods imported into the United States. The proposals target three areas: 1. enhanced identification of parties involved in importation; 2. integration of technical tracing solutions; and 3. collection of foreign export documentation.  Crowell is available to provide support to clients in preparing responses to CBP’s ANPRM, in advance of CBP’s deadline on December 1, 2026.