Photo of Boaz I. Green

In March of this year, the Consumer Product Safety Commission (CPSC) announced that it would interpret the Child Nicotine Poisoning Prevention Act of 2015 (CNPPA) as mandating specific flow-restrictor requirements for liquid nicotine containers that are sold, offered for sale, manufactured for sale, or distributed in commerce. CPSC soon began aggressive enforcement of its new

Small businesses are facing serious compliance burdens as a result of the Consumer Product Safety Commission (CPSC)’s recent interpretation of the Child Nicotine Poisoning Prevention Act (CNPPA). Keller and Heckman partner Sheila Millar testified on behalf of the E-Vapor Coalition about the adverse impact at the Small Business Administration’s (SBA) regulatory fairness hearing held on

As we reported previously, the Consumer Product Safety Commission (CPSC) recently announced that it considers flow restricted containers for nicotine containing e-liquids to be required under the Child Nicotine Poisoning Prevention Act of 2015 (CNPPA). Boaz Green was interviewed by Regulator Watch regarding CPSC’s recent enforcement actions, industry’s response, and the options available

As previously reported on this blog, earlier this year, the U.S. Consumer Product Safety Commission (CPSC) announced that it was now reading the Child Nicotine Poisoning Prevention Act (CNPPA) to require nicotine e-liquid bottles to meet the “restricted flow requirement” in 16 C.F.R. § 1700.15(d), in addition to having child-resistant closures. A wave of enforcement

Since the Child Nicotine Poison Prevention Act (CNPPA) became law in 2015, liquid nicotine in containers “from which nicotine is accessible through normal and foreseeable use by a consumer” (such as e-liquid bottles) have been required to utilize child-resistant packaging pursuant to the Poison Packaging Prevention Act (PPPA) and its implementing

We have observed two recent enforcement trends at the Consumer Product Safety Commission (CPSC) that may affect the e-vapor industry: (1) a spike in recalls of products harmful or fatal to children if ingested but lacking required child-resistant packaging; and (2) an increased focus on the absence of certificates of compliance. Both forms of regulatory