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New York Court Invalidates Cleaning Product Ingredient Disclosure Requirements

On August 27, 2019, a New York judge struck down New York’s cleaning product ingredient disclosure program, finding that the program constituted a regulation and that it had not been promulgated in accordance with the State Administrative Procedure Act (SAPA). In 2018, the New York State Department of Conservation (DEC) drafted requirements entitled “Household Cleansing Product Information Disclosure Program.” Originally set to become effective in July 2019, with enforcement then pushed back to October 2019, the Disclosure Program imposed significant obligations on cleaning product manufacturers, including a requirement to disclose all intentionally added ingredients even if present only in trace…

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Nicotine Vape Products: A Safer Alternative?

By Grimaldi Law Offices Summer Associate Cecilia Grimaldi An increasing wave of mysterious respiratory illness related to vape product use has triggered government action. The Centers for Disease Control has advised people to stop the use of e-cigarettes and other vaping products.  The Food and Drug Administration has also warned the largest American e-cigarette brand, Juul, to cease promotion of its products as a safer alternative to cigarettes. Further, the Trump administration has announced plans to ban flavored e-cigs. While agencies such as the FDA now are beginning to take action against the smoking alternative, there are concerns they failed…

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The Circular Economy: What It May Mean For Your Business

By Grimaldi Law Associate Jennifer Singh The Circular Economy (CE) concept is a growing trend in sustainability that is gaining popularity worldwide in both the private and public sectors. The phrase describes the global effort made across all industries to reduce waste and redesign the way that finite resources are used to ensure that materials are kept in a loop of reusability for as long as possible. To achieve a CE that produces non-toxic and reliable recycled materials, its proponents maintain that prioritizing chemical standards plays a crucial role. Although chemical legislation has not yet fully adapted to CE approaches,…

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OEHHA Schedules DARTIC Meeting on Cannabis

The California Office of Environmental Health Hazard Assessment (OEHHA) has set December 11, 2019 for the meeting of the Developmental and Reproductive Toxicant Identification Committee (DARTIC). At that meeting, the DARTIC will determine whether to identify the following cannabis-related substances as reproductive toxicants under Proposition 65: cannabis (marijuana), cannabis smoke (marijuana smoke), cannabis extracts, and Δ-9-Tetrahydrocannabinol (THC). OEHHA issued a data call-in request on these substances on March 15, 2019. Several comments were submitted, many of which requested that the DARTIC review be clear about what, exactly, is being considered for listing. For example, the Personal Care Products Council stated…

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Not So Fast…The FTC Issues Warning Letters to CBD Companies

On September 10, 2019, the Federal Trade Commission (FTC), whose mission is “[p]rotecting consumers and competition by preventing anticompetitive, deceptive, and unfair business practices,” issued warning letters to three companies that sell products containing cannabidiol (CBD).  The letters allege that the companies have made unsubstantiated health claims, including claims that the products have been proven to treat anorexia, fibromyalgia and Alzheimer’s disease. According to the FTC, such claims are illegal if made without competent and reliable scientific evidence. These warning letters follow other warning letters issued jointly by the FTC and the Food and Drug Administration (FDA) earlier this year.…

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