Safety is at the core of the U.S. Consumer Product Safety Commission’s (CPSC) mission, which ensures that consumer products meet rigorous standards to safeguard against risk. Sidley’s Consumer Product Safety Regulatory practice helps clients meet that mandate by aligning their products, practices, and compliance programs with the CPSC’s safety-driven requirements. Our team helps clients navigate the complex and evolving regulatory landscape for consumer products in the United States and abroad. We have extensive experience counseling clients on reporting obligations, defending against and navigating product recalls, developing robust safety and compliance programs, and related matters associated with and overseen by the CPSC. What sets Sidley apart is not just our mastery of the legal framework and precedent, but our hard-earned credibility with the agency and insights into the Commission’s decision-making process. With a deep understanding of the Commission’s regulations and a history of working strategically with the agency, we help clients mitigate consumer safety risks and maintain compliance.
Our expertise also extends to responding to enforcement actions, including civil penalty investigations, as well as carry-on complex litigation often filed in the aftermath of announced product recalls. We also leverage Sidley’s multidisciplinary capabilities in product liability, consumer class actions, regulatory, and environmental law to provide holistic and business-oriented advice to clients facing product safety challenges and litigation risks. Whether our clients need guidance on compliance, investigation, negotiations, business decisions, or are facing potential litigation, we offer practical, efficient, and effective solutions that protect their business interests and reputation with the highest level of service.
Sidley Provides Full-Service Counsel By:
- Interpreting and advising clients on general and product-specific safety standards enforced by the CPSC, including testing, certification, importation, packaging, and labeling requirements.
- Advising clients on internal and external product risk investigations.
- Counseling clients at all stages of a consumer product’s life cycle on CPSC reporting requirements pertaining to potential product safety concerns.
- Communicating with the CPSC regarding product safety issues, regulatory compliance, Notices of Violation, and potential recalls.
- Responding to complaints published on CPSC’s consumer complaint database.
- Developing and negotiating the terms of product recalls, including corrective action plans.
- Proactively and reactively designing internal compliance programs.
Recent Representative Matters
Our lawyers have routinely counseled manufacturers, distributors, importers, and retailers across a broad range of industries on all aspects of CPSC compliance and challenges, among them:
- Negotiating the terms and scope of product recalls involving home appliances, electronic devices, clothing, home spa products, and plumbing appliances.
- Successfully arguing to the CPSC that subject products did not contain defects which could create a substantial product hazard or create an unreasonable risk of serious injury.
- Persuading the CPSC to decline assessment of any civil penalty in connection with its investigation into alleged violations of Section 15’s reporting requirements under the Consumer Product Safety Act (CPSA).
- Advising a manufacturer of electronic devices regarding CPSC reporting requirements and the terms of a recall pertaining to a product fire risk.
- Counseling a client on correspondence with the CPSC in response to a Notice of Violation pertaining to imported consumer products.
- Advising a client on the investigation of safety risks and potential CPSC reporting pertaining to roofing panels.
- Engaging with an engineering expert to conduct a product investigation and limit the scope of a product recall.
- Advising a product manufacturer regarding CPSC reporting requirements in response to a burn risk associated with an electronic appliance.
- Interpreting Children’s Product Certificate (CPC) requirements imposed by the Consumer Product Safety Improvement Act (CPSIA).
- Analyzing tracking label requirements applicable to a client’s children’s products.
- Conducting diligence on CPSC-related risks applicable to off-road vehicles.
- Educating clients on requirements imposed by various regulations, including the CPSA, the CPSIA, the Federal Hazardous Substances Act (FHSA), and the Poison Prevention Packaging Act (PPPA).
How We Add Value
Drawing on our breadth of experience, Sidley takes a multidisciplinary approach and holistic view of our clients’ needs. We harness knowledge from, and provide CPSC insight to, our Product Liability, Consumer Class Actions, and U.S. and international regulatory and environmental practices to advise on product safety issues and reporting requirements, while helping to minimize litigation risks and creating business-oriented solutions to product safety concerns.
Recent Representative Matters
We have routinely counseled large online retailers, clothing manufacturers and retailers, electronic device manufacturers, healthcare companies, home appliance manufacturers, and clients in numerous other industries on all aspects of CPSC compliance, from interpreting children’s product testing requirements to advising on product packaging regulations to negotiating with CPSC over the terms of product recalls.
Our lawyers recently have assisted clients in navigating a wide array of challenges, including:
- Advising a manufacturer of electronic devices regarding CPSC reporting requirements and the terms of a recall pertaining to a product fire risk.
- Negotiating the terms of a recall pertaining to a clothing product.
- Counseling a client on correspondence with the CPSC in response to a Notice of Violation pertaining to imported consumer products.
- Advising a client on the investigation of safety risks and potential CPSC reporting pertaining to roofing panels.
- Engaging with an engineering expert to conduct a product investigation and limit the scope of a product recall.
- Negotiating with the CPSC over the terms of a recall pertaining to a home spa product involving a fire risk.
- Advising a product manufacturer regarding CPSC reporting requirements in response to a burn risk associated with an electronic appliance.
- Interpreting Children’s Product Certificate (CPC) requirements imposed by the Consumer Product Safety Improvement Act (CPSIA).
- Analyzing tracking label requirements applicable to a client’s children’s products.
- Conducting diligence on CPSC-related risks applicable to off-road vehicles.
- Educating clients on requirements imposed by various regulations, including the Consumer Product Safety Act (CPSA), the CPSIA, the Federal Hazardous Substances Act (FHSA), and the Poison Prevention Packaging Act (PPPA).
Accolades
Ranked Band 1 in Product Liability: Regulatory; Recognized as an Elite Nationwide Practice for Product Liability & Mass Torts; and multiple partners nationally ranked in Product Liability & Mass Torts
— Chambers USA 2025
Tier 1 in National Ranking for Mass Tort Litigation/Class Actions – Defendants
— U.S. News; — Best Lawyers® “Best Law Firms” Survey 2025
Tier 1 in Nationwide Product Liability and Recall
— Benchmark Litigation 2025
Tier 1 in Product Liability and Finalist for “Product Liability Firm of the Year”
— LMG Life Sciences 2024
Named a BTI “Litigation Powerhouse” in Product Liability Litigation
— BTI Litigation Outlook 2025
Winner for “Products Liability/Mass Torts Litigation Department of the Year”
— New York Law Journal 2024
