A new bill introduced in the California legislature proposes to overhaul the state’s product recall liability framework—and depending on where you sit in the supply chain, the consequences could be far-reaching. Assembly Bill 2462 would amend the state’s Product Recall Safety and Protection Act to redefine who qualifies as a “manufacturer,” broaden the scope of cost-free recall obligations, and dramatically increase penalties for violations. Introduced by Assembly Member Pellerin on February 20, 2026, the bill’s provisions would apply across the consumer product supply chain, touching manufacturers, importers, distributors, wholesalers, retailers, and, most notably, brand licensors.

Continue Reading The Hidden Recall Risk in Your Licensing Agreement: What California’s Assembly Bill 2462 Could Mean for Your Business

Register now to join Crowell & Moring for “Between the Lines: What CPSC Enforcement Data Reveals for 2026 and Beyond” to explore the latest regulatory enforcement trends and gain a forward-looking perspective on what 2026 and beyond may bring. The webinar will take place on Thursday, May 7, 2026 from 2:00 – 3:00 p.m. ET.

Continue Reading Register Now! Between the Lines: What CPSC Enforcement Data Reveals for 2026 and Beyond

The year 2025 saw an increase in recall class actions challenging false advertising, labeling, and recall remedies across consumer goods, from household products to pet food. One persistent question for courts in these recall cases is whether the plaintiff has Article III standing, which often hinges on “traceability.” These cases do not appear to be slowing down in 2026, as consumers are becoming even more conscious and selective about the products they purchase, driving greater scrutiny and risk for product companies across all industries.

Continue Reading 2025 Recall Class Action Wave: False Advertising, Mislabeling, and Traceability Shape the Litigation Trends

Register now to join Crowell & Moring for “Recall Execution Bootcamp: Practical Skills for Fast-Track Recalls,” a webinar that will cover the fundamental steps and considerations to execute a recall in a manner that minimizes business disruption and ensures compliance with regulatory expectations. This webinar will take place on Thursday, January 22, 2026 from 3:00 – 4:00 p.m. ET.

Continue Reading Register Now! Recall Execution Bootcamp

On August 5, 2025, the CPSC and the DOJ announced a defunct New Jersey importer of consumer appliances pled guilty to one count of willfully violating the Consumer Product Safety Act for its failure to report dangerous defects in portable air conditioners that had been linked to multiple fires and one death.

Continue Reading When Silence Speaks: How Saying Nothing Led to a Defunct New Jersey Importer Pleading Guilty to Criminal Charges for Failing to Report to the CPSC

On June 16, 2025, the first-ever sentences were handed down in a criminal prosecution for failure to report under the Consumer Product Safety Act (CPSA). Judge Dale S. Fischer of the U.S. District Court for the Central District of California sentenced two former Gree USA, Inc. (Gree USA) executives to 38 and 40 months in prison, respectively, for conspiracy to defraud the U.S. Consumer Product Safety Commission (CPSC) and for failure to report information related to defective dehumidifiers under Section 15 of the CPSA.

Continue Reading Corporate Executives Are Sentenced in First-Ever Criminal Prosecution for Failure to Report Under the CPSA

On May 5, 2023, the U.S. Consumer Product Safety Commission (“CPSC”) announced that it agreed to a civil penalty settlement with Generac Power Systems, Inc., (“Generac”) to resolve charges that Generac failed to report immediately to the CPSC under Section 15(b) of the Consumer Product Safety Act (“CPSA”). Specifically, the CPSC alleged that certain models of Generac’s portable generators contained a defect that could create a substantial product hazard and unreasonable risk of serious injury to consumers. This settlement includes a $15,800,000 civil penalty, and requirements that Generac (1) implement and maintain a compliance program and system of internal controls and procedures designed to ensure compliance with the CPSA; and (2) file annual reports with the agency for the next three years regarding the Company’s compliance program, internal controls and procedures, internal audits of the effectiveness of the new compliance program and internal controls.

Continue Reading CPSC and Company Reach Agreement on $15.8 Million Civil Penalty for Failure to Report

Last Thursday, April 6, the Department of Justice (DOJ) and Consumer Product Safety Commission (CPSC) sued SunSetter Products LP (SunSetter) in a Massachusetts federal court in a rare civil penalty lawsuit. SunSetter manufactures motorized retractable awnings for outdoor use. The Government alleges in its complaint that SunSetter knowingly failed to timely report under Section 15(b) of the Consumer Product Safety Act (CPSA) a hazardous defect related to vinyl covers for its retractable awnings. The complaint seeks permanent injunctive relief, including a third-party monitorship over the company, and civil penalties.

Continue Reading CPSC Seeks Civil Penalty Against SunSetter in Rare Federal Court Action

Companies faced with a potential product recall are often concerned with possible adverse publicity and increased litigation risk. But a quick and comprehensive recall can be the very tool that stops a lawsuit in its tracks. In a recent Law360 article titled, “Quick and Comprehensive Recall Moots Claims and Proves an Effective Tool in Defeating