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FDA to Expand Unannounced Inspections of Foreign Facilities — Manufacturers, Research Firms Should Prepare

By Clint Narver, Mindy Sauter, Michael F. Easley, Jr. & Rhea Shahane on May 22, 2025
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On May 6, 2025, the U.S. Food and Drug Administration (FDA) announced a plan to expand its use of unannounced inspections of foreign manufacturing facilities that produce foods, essential medicines and other medical products intended for American consumers and patients. The FDA stated that this new inspection strategy will ensure that foreign manufacturers receive the same level of oversight and regulatory scrutiny as domestic companies. Key aspects of the FDA’s plan include:

  • Increased Frequency: The FDA will increase the frequency of unannounced inspections at foreign facilities.
  • Elimination of Double Standard: The FDA stated that the move ensures that foreign manufacturers are held to the same standards and oversight as domestic companies.
  • Exposing Bad Actors and Ensuring Safe Prescription Drugs: The FDA explained that unannounced inspections will help expose bad actors (e.g., those who falsify records or conceal violations) and ensure that every product entering the U.S. is safe, legitimate and honestly made.
  • Increased Enforcement Activity: The FDA emphasized that it is authorized to take regulatory action against any company that attempts to delay, deny or limit an unannounced inspection.

Read on to learn more about the FDA’s new policy and key considerations for stakeholders.

Photo of Clint Narver Clint Narver

Clint excels at handling complex legal problems with creativity and tact in situations where clients cannot afford to lose. A former federal prosecutor and member of the firm’s nationally ranked Government Investigations and White Collar Litigation Department, Clint represents companies and individuals in…

Clint excels at handling complex legal problems with creativity and tact in situations where clients cannot afford to lose. A former federal prosecutor and member of the firm’s nationally ranked Government Investigations and White Collar Litigation Department, Clint represents companies and individuals in high-stakes white collar matters and strategically advises on U.S. Food and Drug Administration (FDA) legal, compliance, and policy issues.

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Photo of Mindy Sauter Mindy Sauter

Mindy boasts an extensive and distinguished career as a trial attorney, having honed her skills at the state level as a county prosecutor and at the federal level as an assistant U.S. attorney. With a wealth of experience spanning numerous high-stakes trials, her…

Mindy boasts an extensive and distinguished career as a trial attorney, having honed her skills at the state level as a county prosecutor and at the federal level as an assistant U.S. attorney. With a wealth of experience spanning numerous high-stakes trials, her legal acumen and courtroom prowess have earned her widespread recognition. Mindy is a co-leader of the firm’s Healthcare Litigation and Enforcement Practice Group.

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Photo of Michael F. Easley, Jr. Michael F. Easley, Jr.

Former U.S. Attorney Michael Easley represents companies, boards, and executives in complex government enforcement actions, internal investigations, and litigation. He has advised clients facing inquiries by the DOJ, SEC, and state attorneys general, helping them navigate enforcement scrutiny, mitigate risk, and resolve complex…

Former U.S. Attorney Michael Easley represents companies, boards, and executives in complex government enforcement actions, internal investigations, and litigation. He has advised clients facing inquiries by the DOJ, SEC, and state attorneys general, helping them navigate enforcement scrutiny, mitigate risk, and resolve complex disputes.

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Photo of Rhea Shahane Rhea Shahane

Rhea represents international companies and individual clients in a wide range of complex litigation matters, with a focus on government and internal investigations. Rhea also represents financial services clients in complex securities matters, focusing on regulatory investigations, enforcement actions, and internal investigations.

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  • Posted in:
    Food, Drug & Agriculture
  • Blog:
    Subject to Inquiry
  • Organization:
    McGuireWoods LLP
  • Article: View Original Source

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