American Conference Institute (ACI)’s second extended producer responsibility (EPR) Think Tank in New York City is gaining traction as “the” leading conference for EPR packaging programs. This year’s conference, held January...more
Extended producer responsibility (EPR) laws are increasingly making companies that market, distribute, and sell packaged consumer products responsible for the cost to dispose of the packaging that they place in the market....more
The scope of products to be drawn into the warning requirements under California’s Proposition 65 law may soon be growing. California’s Office of Environmental Health Hazard Assessment (OEHHA) requested information from the...more
Businesses that sell consumer products in California should be aware of upcoming changes to recycling label restrictions. Recently enacted California law requires that all products and packaging manufactured after October 4,...more
In a crowded marketplace where label claims often serve as a key point of differentiation, brands frequently push the boundaries of what may or may not be permissible under applicable regulations. This dynamic can create...more
Update (Jan. 22, 2026): Following publication of this article, Judge William H. Orrick certified a class of California consumers in Jeruchim et al. v. The J.M. Smucker Co. et al. (N.D. Cal.). Our analysis below reflects the...more
Contaminants Compass is a monthly newsletter that provides updates, legal observations and actionable tips to navigate the evolving legal challenges of per- and polyfluoroalkyl substances (PFAS) and similar chemicals and...more
Introduction: A paradigm shift in environmental marketing - Greenwashing, the practice of overstating or misrepresenting environmental benefits, has been a key focus of corporate marketing scrutiny for several years....more
Since Holland & Knight's previous alert about state extended producer responsibility (EPR) laws for packaging, there have been significant developments in the implementation of these programs. Seven states currently have EPR...more
A class action lawsuit against J.M. Smucker Co. filed in California federal court is nearing certification. Plaintiffs allege Smucker failed to warn consumers of potential risks associated with per- and polyfluoroalkyl...more
To ring in the new year, New Jersey became the latest state to enact legislation banning intentionally-added PFAS in certain consumer products. In the final days of his term, Governor Murphy signed into law the Protecting...more
What Happened? California - On January 9, 2026, California’s Department of Resources Recycling and Recovery (CalRecycle) withdrew its proposed regulations implementing the Plastic Pollution Prevention and Packaging...more
Texas AG Ken Paxton announced a settlement with Procter & Gamble Manufacturing Company (“P&G”), the manufacturer of Crest toothpaste, resolving allegations that the company deceptively marketed children’s fluoride toothpaste....more
On January 9, 2026, the California Department of Resources Recycling and Recovery (CalRecycle) officially withdrew its proposed regulations for the Plastic Pollution and Packaging Producer Responsibility Act (SB 54) from the...more
The US Food and Drug Administration (FDA) issued an inspectional observation (Form FDA 483) to a Texas med spa, Pure Indulgence Aesthetics, citing Drug Supply Chain Security Act (DSCSA) violations for dispensers....more
In December 2025, the California Office of Environmental Health Hazard Assessment (OEHHA), the state agency responsible for implementing Proposition 65 (Prop 65), issued two “Information Letters” regarding Prop 65 compliance...more
Key Takeaways - What Happened: On December 16, 2025, the Washington Department of Ecology (Ecology) adopted a new rule – the Battery Stewardship Program, Chapter 173-905 WAC – to implement and clarify requirements under...more
If you are taking (or have recently taken) a prescription drug that is now subject to a recall, there are several important facts you need to know. One of these facts is why your prescription was recalled. ...more
Extended producer responsibility (EPR) is increasingly recognized as a core factor in transactional due diligence in the United States, with real cash costs, operational implications, and liability exposure that can...more
The United States House of Representatives Congressman Randy Weber (Texas) introduced legislation titled: The Packaging and Claims Knowledge Act of 2025 (“PACK Act”)....more
The first wave of prohibitions on per- and polyfluoroalkyl substances (PFAS) in cosmetics and cosmetic products took effect earlier this year, with bans in California, Colorado, Maryland, Minnesota, and Washington commencing...more
Companies across industries continue to face increasing production costs. Whether due to tariffs, inflation, supply chain disruptions, or simply a shortage of raw materials, the rising costs of goods have hit every part of...more
Effective last January 1, 2025, California’s extended producer responsibility (“EPR”) packaging and food service ware program, the Plastic Pollution Prevention and Packaging Producer Responsibility Act (the “Act" or "SB 54"),...more
On December 2, 2025, the California attorney general issued a formal enforcement advisory letter to producers of food-service ware made from expanded polystyrene foam (EPS). The letter reminds producers that under California...more
Congressman Lou Correa introduced the Design for Recycling Resolution (“Resolution”) that is described as recognizing and encouraging: … efforts by manufacturers to reduce waste and consumption of raw materials by...more