The title takes effect on October 1, 2025 or on enactment, but the fees run from October 1, 2025
What the document says“The amendments made by this title shall take effect on October 1, 2025, or the date of the enactment of this Act, whichever is later, except that fees under part 10 of subchapter C of chapter VII of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 379j-71 et seq.) shall be assessed beginning October 1, 2025, regardless of the date of the enactment of this Act.”
The Act was signed on November 12, 2025, so the amendments took effect that day. The fees are the exception: they are charged from the start of the fiscal year whatever the date of signing.
What the document actually says“The amendments made by this title shall take effect on October 1, 2025, or the date of the enactment of this Act, whichever is later, except that fees under part 10 of subchapter C of chapter VII of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 379j-71 et seq.) shall be assessed beginning October 1, 2025, regardless of the date of the enactment of this Act.”
The changes start on the later of two dates. The fees are charged from October 1, 2025 no matter what.
The budget year began in October. The law was signed in November. The fees still run from the start of that year.
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