New York State is quickly ramping up its regulation of chemicals as it relates to consumer products. First, the New York State Department of Environmental Conservation (“DEC”) promulgated new regulations last year, known as the Household Cleansing Product Information Disclosure Program (“Program”), that will be effective starting October 2, 2019. The Program will, among other things, require manufacturers to disclose on their website the ingredients of household cleansing products that are “distributed, sold, or offered for sale” in New York State, and “the nature and extent” of any research and investigations on the ingredients’ effects on human health and the environment.
More recently, in March, State legislators introduced companion bills (A6296A and S501B), known as the Child Safe Products Act (“Act”), that will require manufacturers of children’s products containing a “dangerous chemical” or “chemical of concern” to make certain disclosures to DEC and others in the distribution chain. If the Act is signed into law as drafted, manufacturers will need to comply by March 1, 2020.
For additional information regarding New York State’s latest chemical regulations for manufacturers, please see our most recent Client Alert.
Phillips Lytle Attorney, Luke Donigan, was assisted in the preparation of this article by Kathryn M. Gantley.