About the Course
Introduction
This CLE webinar will navigate rapidly expanding state PFAS bans, the federal regulatory overlay, and managing compliance across complex ingredient and packaging supply chains. The panel will examine this emerging patchwork, distilling best practices for product teams, procurement, and legal so companies can keep product deliverables while reducing enforcement and litigation exposure.
Description
As more jurisdictions restrict cosmetics containing intentionally added PFAS, companies face inconsistent statutory definitions, staggered effective dates, and real uncertainty around trace/technically unavoidable PFAS. At the same time, federal developments, including FDA activity under MoCRA and EPA's TSCA PFAS reporting requirements, are increasing pressure on traceability, documentation, and the defensibility of "PFAS-free" or "clean" product claims.
The panel will discuss best practices to build a responsive compliance program from understanding the developing state law matrix to tightening supplier specifications, certifications, audit rights, and change-control clauses. They will discuss testing, recordkeeping, and aligning marketing/label review to minimize risk.
Listen as our panel examines how to manage PFAS cosmetics bans, including supply chain controls, documentation strategy, and risk reduction.
Presented By
Mr. Thurlow is an environmental and toxic tort litigator. He represents clients in state and federal courts across the country, including in multidistrict litigation, in high-stakes matters involving environmental, product liability, consumer product and advertising, and personal injury claims relating to chemicals including per- and polyfluoroalkyl substances (PFAS), ethylene oxide, dioxins, and PCBs. Mr. Thurlow frequently represents clients in civil enforcement and private party lawsuits brought under the Clean Air Act, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Resource Conservation and Recovery Act (RCRA), Clean Water Act, Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and Toxic Substances Control Act. Drawing on his deep understanding of emerging contaminant issues in product liability, environmental, and personal injury cases, he also advises companies on their regulatory compliance and reporting obligations under federal and state laws related to PFAS in consumer products.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Tuesday, March 17, 2026
- schedule
1:00 p.m. ET./10:00 a.m. PT
I. PFAS in cosmetics and where it enters the chain
II. The state patchwork: What is banned, when, and how terms differ
III. Packaging and downstream exposure
IV. Compliance
A. Specifications, testing, vendor management, documentation
B. Contract clauses and audit/traceability
V. Federal overlay and what to watch next: EPA's TSCA, FDA's MoCRA
VI. Enforcement, investigations, and disputes
VII. Best practices and takeaways
The panel will discuss these and other key areas:
- Where PFAS risk hides in cosmetics programs, including inputs, processing aids, and packaging
- Distinguishing "intentionally added" from impurities/trace and what that means for compliance
- Understanding the multistate compliance requirements and federal overlay
- Drafting supplier-facing terms: PFAS reps/warranties, disclosure duties, audit rights, and change-control
- "PFAS-free" marketing exposure and substantiation-ready internal records and review workflows
Related Courses
PFAS in Cosmetics: State Bans, Supply Chain Proof, and Labeling
Tuesday, March 17, 2026
1:00 p.m. ET./10:00 a.m. PT
Environmental Insurance Coverages: CGL, Property, and D&O Policies for PFASs, ESG, NRS, CERCLA, RCRA, OPA, and Others
Thursday, February 26, 2026
1:00 p.m. ET./10:00 a.m. PT
