Seller Beware: California Announces Draft Plan for New Consumer Product Categories Under Its Green Chemistry Initiative

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California’s toxics agency, the Department of Toxic Substances Control (DTSC), has released a draft three-year work plan identifying seven consumer product categories that may be the focus of the state’s Green Chemistry Initiative. The innovative new law requires product manufacturers to examine whether they can replace existing chemical ingredients with alternatives that are deemed safer for consumers and the environment. For many consumer product companies, the regulations will require major investments in compliance and changes to product design planning and supply chain management. A more detailed description of these requirements can be found at Morrison & Foerster’s Green Chemistry web page.

On September 12, 2014, DTSC released its Draft Priority Product Three Year Work Plan. The draft work plan identifies seven product categories from which priority products will be selected for regulation over the coming three years, as well as some of the considerations that resulted in DTSC’s product category selections...

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