FTC changes premerger notification rules for drug patents

Managing IP is part of Legal Benchmarking Limited, 1-2 Paris Gardens, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

FTC changes premerger notification rules for drug patents

The FTC has issued final changes to the premerger notification rules governing how pharmaceutical companies must report the acquisition of exclusive patent rights to the FTC and the Antitrust Division of the Department of Justice (DOJ)

Under the Hart-Scott-Rodino (HSR) Act, drug companies must report certain mergers and acquisitions of assets, including patents and exclusive patent licences, over a certain amount to the FTC and DOJ. The current threshold is $70.9 million.

The change will revoke the existing “make, use and sell” standard governing which licences are reportable. Under the current rules, companies are only required to report transfers of patent licences if they allow the buyer to develop, manufacture and sell a product without restriction.

Under the new rules, pharmaceutical companies will have to report transfers falling under the scope of the more stringent “all commercially significant rights” test.

According to the FTC, this will mean that “an exclusive license is substantively the same as buying the patent or part of the patent outright, and carries the same potential anticompetitive effects".

The FTC claims the “make, use and sell” test is “no longer adequate” because some drugs companies were transferring most but not all of the rights under a licence in order to avoid the reporting requirement.

The FTC received four public comments on the rule, including an objection to it from industry organisation Pharmaceutical Research and Manufacturers of America.

The new rules will take effect 30 days after publication in the Federal Register.

more from across site and SHARED ros bottom lb

More from across our site

Loke Khoon Tan and Stephanie Yip at Dentons explain what brand owners need to know ahead of January 1 2027, when updates to China’s Trade Mark Law come into force
New US bills signal that firms should work with clients to ensure they are complying with potential regulatory requirements
Octavio Espejo of Becerril, Coca & Becerril explains how sweeping patent reforms reshape filing strategies, prosecution, and divisional application practice
The UK Supreme Court’s decision in Tesla v Avanci enhances the UK's attractiveness for global FRAND battles, say lawyers at Simmons & Simmons
PE-backed practices now comprise the majority of ranked firms for patent prosecution in the Netherlands, but competitors are confident about their decision to remain independent
The firm says new additions position Brown Rudnick as a market leader in tech, life sciences, and global litigation
Richard Quatrano, counsel at Olshan Frome Wolosky, shares why technology M&A buyers and sellers must verify written IP assignments, as broken ownership chains can undermine valuation, deal terms, and closing certainty
Appointment of AI and copyright expert Anna Naydonov, as well as another partner from Orrick, shows how firms can attract top litigators through leveraging the power of their existing teams
K&L Gates and Baker Botts have recruited leading patent practitioners from Wende IP and EIP, respectively, as they seek to strengthen European patent litigation capabilities
The departure of a large chunk of Spruson & Ferguson's legacy leadership could have destabilised the firm, but it's fighting back with strategic hires and promotions
Gift this article