With the largest consumer market in the nation, California has adopted new regulations to implement its Green Chemistry Initiative (GCI), a bold new environmental law to identify and restrict toxic chemicals in consumer products sold in the state. The law requires a new life-cycle “alternatives analysis” to evaluate alternatives and substitutes for hazardous substances in consumer products based not only upon their risk during product use, but also during their manufacture and after disposal. The state may then condition, restrict or ban the use of those chemicals in the products of concern.
The law is contained in California’s Assembly Bill 1879 (AB 1879), Senate Bill 509 (SB 509) and the Safer Consumer Product Regulations, which were approved by the Office of Administrative Law on August 28, 2013 and became effective on October 1, 2013. We will be updating this page regularly with client alerts, links and presentations in order to provide you with updates and in-depth analyses of this initiative.
MoFo lawyers have worked on product stewardship and chemical use issues since the 1980s, including in agency rulemaking, litigation and requirements imposed by the U.S. Consumer Product Safety Act, California’s Proposition 65, EU’s REACH, RoHS and WEEE Directives, as well as China RoHS. We have followed the scientific debate on the Green Chemistry Initiative throughout its history and can help you understand how the new regulations may affect your business operations, including:
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