California has delayed the effective date of new regulations drafted to implement the state’s Green Chemistry Initiative. As discussed in our blog post of November 22, 2010, California planned to implement the regulations on January 1, 2011. If the regulations had been implemented on that date, how companies designed and manufactured consumer products sold, offered for sale, distributed, supplied, or manufactured for use in California would have changed dramatically.

On December 23, 2010, California’s Secretary for Environmental Protection, in a letter to Assembly Member Mike Feuer (the author of the law that led to these regulations), indicated that California’s Department of Toxic Substances Control (“DTSC”) had “agreed to take additional time to be responsive to the concerns raised [by stakeholders] and revisit the proposed regulations. I believe this extra time will allow us to create a workable program and address critical policy issues, such as third party verification and [product] prioritization.” A copy of this letter is available on DTSC website at

DTSC is expected to reconvene the Green Ribbon Science Panel in early February 2011. According to the December 23rd letter, the panel is expected “to further vet the programmatic issues” raised by various stakeholders during the 2010 public comment process. No further news is publicly available at this time as to when, and if, DTSC will amend the proposed regulations and permit additional public review and comments.

Content for this post was provided by Kevin Mayer in the Los Angeles office and Matthew Jaffe in the Washington, DC office of Crowell & Moring.