Product Stewardship

Verdant Law helps companies anticipate, manage, and comply with evolving product stewardship requirements across the entire product lifecycle.

Product stewardship has become one of the fastest-evolving areas of environmental law. Around the world, governments are expanding requirements governing chemicals, product safety, packaging, recycling, supply chain transparency, and other sustainability-related obligations. Market pressure is also building. Customers, retailers, investors, and downstream commercial partners increasingly demand visibility into product composition, lifecycle impacts, and responsible sourcing practices.

These developments influence far more than regulatory compliance. They shape product design, material selection, labeling, market access, reporting, and end-of-life responsibilities. Companies that anticipate change are better positioned to avoid disruption, strengthen supply chains, protect their brands, and bring products to market with confidence.

Verdant Law takes a lifecycle view of product-related risk. We advise clients at every stage — from sourcing materials and managing supplier obligations through manufacturing, labeling, distribution, retail, and end-of-life requirements. Our attorneys work with manufacturers, importers, distributors, retailers, and downstream users across a broad range of industries. We develop practical, forward-looking strategies that help clients navigate product stewardship requirements in the United States and around the world.

Our work includes advising clients on:

  • Chemical content and product restrictions under TSCA, REACH, and analogous frameworks governing substance prohibitions, use restrictions, and disclosure obligations.
  • PFAS, microplastics, and other emerging contaminants, including product-specific use prohibitions, disclosure and labeling requirements, and supply chain due diligence obligations arising from domestic and global restrictions.
  • Packaging, recycling, and extended producer responsibility (EPR), including U.S. state programs and international frameworks.
  • Product safety, labeling, and warnings, including CPSC regulations, California Proposition 65, VOC restrictions, and FIFRA requirements.
  • Supply chain due diligence and transparency, including vendor audits, contractual compliance obligations, raw material due diligence, and responsible sourcing obligations.
  • FFDCA food contact substances, including food contact notifications, interpretation and application of indirect food additive regulations, and pursuance of exemptions such as TOR, GRAS, and TTC.
  • Regulatory enforcement matters and investigations, including product take-back programs.
  • Product stewardship considerations in transactions and commercial agreements, including diligence, representations and warranties, and supply chain contracting.
To discuss your product stewardship needs, please email info@verdantlaw.com or call +1 202-828-1233.

RECENT HIGHLIGHTS

PFAS Labeling Litigation

Filed comments on, and initiated litigation against, New Mexico’s PFAS labeling rule on behalf of a domestic consumer products manufacturer.

Secured VOC Deadline Delay

Through litigation before the D.C. Circuit, obtained delayed compliance deadlines for EPA’s 2025 updates to the National VOC Emission Standards for Aerosol Coatings.

Food Contact TTC Analysis

Advised a food colorant manufacturer on the food-contact status of substances through TTC analyses.

FIFRA Treated Articles

Counseled a consumer products company on achieving compliance with the FIFRA treated articles exemption while adhering to related FTC advertising guidance.

Maine PFAS CUU Application

For a domestic product manufacturer, submitted a currently unavoidable use application for coatings under Maine’s PFAS-in-products regulatory scheme.

FIFRA-Avoidant Labeling

Advised a cleaning product manufacturer on product labeling to ensure claims did not trigger FIFRA jurisdiction.

Timely Packaging EPR Compliance

Counseled a paint company on packaging EPR deadlines, achieving timely compliance and managing enforcement risk.

EPA/CARB VOC Compliance

Guided a product manufacturer on compliance with EPA and CARB VOC product restrictions.

SCP Microplastics Comments

On behalf of a microencapsulation polymer manufacturer, submitted comments on DTSC’s proposed regulation of microplastics under California’s SCP Program.

CPSC Incident Response

For a consumer product manufacturer, oversaw a hazard analysis and FHSA-related labeling changes in response to a CPSC incident report.

Nano Reporting Assessment

On behalf of an international coatings manufacturer, managed an assessment of a substance’s nano reporting obligations.

FROM THE BLOG

OTHER PRACTICE AREAS