100% Tariffs Impacting the Pharmaceutical Industry: Section 232, Complex Multi-Tiered Rate Structure, Exemptions

For more than four decades, Mr. Bass has advised companies and governments on compliance, regulatory, and commercialization issues across the United States, Europe, and Asia, advising a majority of the top pharmaceutical, medical device, and dietary supplement manufacturers, distributors, and Contract Research Organizations in bet-the-company regulatory, enforcement, and commercialization matters. He is recognized for his strategic guidance at the intersection of innovation, compliance, and enforcement—particularly where regulatory risk meets business-critical deals. Mr. Bass has led the defense of high-stakes criminal and civil investigations, managed complex audits, and brings the benefit of formal mediator training to resolve entrenched disputes with efficiency. Mr. Bass is considered the foremost authority on U.S dietary supplement law. One of the principal drafters of the Dietary Supplement Health and Education Act, he has authored three books on the subject and is co-author of a recent New England Journal of Medicine article on necessary changes to that law. He has served as counsel to many of the top associations in this field, including the global OTC drug federation.

Ms. Gustafson focuses her practice on U.S. customs and international trade matters. She advises multinational clients in a wide range of customs and trade areas including customs valuation, classification, country of origin, preferential trade programs, mergers and acquisitions due diligence, import compliance, reconciliation, duty mitigation, compliance reviews, and disclosures. Prior to joining the firm, Ms. Gustafson served as a customs and international trade consultant for multinational professional services organizations. She brings extensive experience in leading valuation planning and duty mitigation strategies, preparing and submitting binding ruling requests to CBP, as well as representing clients in CBP audits and inquiries. Ms. Gustafson received her Customs broker license in 2021.

Ms. McNulty advises U.S. and international clients on a range of complex international trade issues, dynamic U.S. and global tariff matters, and related trade compliance questions, including tariff stacking. She provides legal, policy, and strategic advice to companies, trade associations, and governments on international economic policy matters, and assists clients in navigating geopolitical risk. She advises clients on the negotiation and enforcement of international trade agreements, including enforcement proceedings arising under the facility-specific rapid response labor mechanism of the USMCA. Ms. McNulty regularly represents clients before U.S. agencies such as the Office of the U.S. Trade Representative (USTR) and the U.S. Department of Commerce, including in proceedings arising under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. She also litigates before the U.S. Court of International Trade and represents clients in antidumping and countervailing duty (AD/CVD) proceedings.