Consumer Products

Steptoe's global consumer products team assists preeminent US and foreign companies involved in manufacturing, importing, and distributing consumer products. Steptoe lawyers specifically help companies dealing with investigations and proceedings before the US Consumer Product Safety Commission (CPSC) as well as in proceedings before other federal and state consumer agencies.

Steptoe assists clients with:

  • Product development, testing, operations, and approval
  • Product safety programs and product liability avoidance
  • Compliance and recall advice including crisis management, voluntary corrective action plans, and Fast Track recall programs
  • Recall implementation
  • Government reporting requirements including Section 15 reports
  • Enforcement matters under a range of statutes and regulatory programs 

The team is closely integrated with Steptoe's products liability and class action practices.  This  permits us to move directly from the agency arena into court to defend the same products when they are the subject of litigation.  Steptoe lawyers monitor litigation, understand the way agencies operate, and work with them, the investigators, and courts to achieve favorable results for our clients.  Our many appearances in front of the Commission staff allow us to anticipate the issues that arise with frequency during a CPSC investigation, and we can assist companies, through a triage response, to work through the process effectively and efficiently.

In Europe, we concentrate on product safety law by sector-specific legislation and by the regulation of chemicals in products.  

See our list of consumer products and CPSC representative matters.

Representative Matters

  • Acting for a Japanese manufacturer of electronic equipment in implementing a pan-European product recall
  • Developing and implementing Fast Track recalls in 20 days to avoid CPSC preliminary hazard determination and allow client to move forward with its business
  • Acting for an American manufacturer to persuade the CPSC and a standards setting body to update an applicable industry standard, leveling the playing field for the manufacturer in the marketplace
  • Representing clothing manufacturers in complying with CPSC lead content reporting requirements
  • Representing a home tools manufacturer in making CPSC Section 15 report and developing recall program to address issues related to imported batteries
  • Acting for an American pool and spa manufacturer to persuade successfully the CPSC that a product recall of the client’s product was unnecessary despite a broad industry recall of competitors’ products
  • Heading off a CPSC regulation of a client’s building material product due to overlapping jurisdiction