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California Chemical Regulators Release Initial List of Consumer Products to be Scrutinized; Wisconsin Manufacturers Should Take Note

March 20, 2014

On March 13, the California Department of Toxic Substances Control (DTSC) released its initial proposed list of products subject to its Safer Consumer Products regulations. The three product/chemical combinations on the draft list are:

  • Spray Polyurethane Foam (SPF) systems containing unreacted diisocyanates (examples of products include some home insulation, weatherizing, and sealing products).
  • Children’s foam padded sleeping products containing Tris (1,3-dichloro-2-propyl) phosphate or TDCPP (examples of products include some cots, bassinets, and play pens).
  • Paint and varnish strippers, and surface cleaners with methylene chloride.

When DTSC finalizes its list through formal rule-making (likely in 2015), manufacturers of listed products will be required to submit a life cycle analysis of the product to DTSC, describing potential alternatives to mitigate exposure of the chemical of concern at all points in the product’s life cycle. After the alternatives analyses are submitted, DTSC may take additional action to regulate the chemicals or products. These additional steps may include regulations on content and use of the chemical or product, recycling programs, or outright bans.

DTSC is expected to propose additional products for listing in October 2014.

Though DTSC’s regulations apply only to products sold in California, they apply to Wisconsin manufacturers that produce products falling within the California regulations. Because the California regulations potentially apply to manufacturers throughout the United States, they are likely to drive changes nationwide, given the size of California’s consumer market. Manufacturers and retailers whose products include "Candidate Chemicals"—chemicals that DTSC may seek to regulate in conjunction with particular consumer products—should monitor regulatory developments at DTSC.

For additional information on DTSC’s regulatory initiatives, including lists of Candidate Chemicals, click here.

If you have questions about DTSC’s proposed rules, or any other consumer product regulation, please contact any member of Godfrey & Kahn’s Products Liability & Torts or Environmental & Energy Strategies Practice Groups.

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