Retail & Consumer Products Law Observer

Retail & Consumer Products Law Observer

Legal Insight for the Retail and Consumer Products Industry

Warren Lehrenbaum

Warren Lehrenbaum

Warren Lehrenbaum is a partner in Crowell & Moring’s Washington, D.C. office. He represents individual companies and trade associations before the U.S. Environmental Protection Agency (EPA), the United States Department of Agriculture (USDA) and the Food and Drug Administration (FDA), where he advocates on behalf of individual products as well as broad policy issues.

Read Warren's bio on Crowell & Moring's website

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Use Foam? You may be subject to a new proposed EPA rule

Posted in Advertising & Product Risk Management, Environment & Natural Resources
EPA has proposed a new rule to restrict the use of seven toluene diisocyanates (TDIs) in consumer products.  TDIs are commonly used in the production of polyurethanes found in foams, coatings, elastomers, adhesives and sealants used in consumer products.  Flexible foams (for cushioning) and rigid foams (for insulation) are the chief uses for TDI. Published… Continue Reading

RCRA Challenges Faced by Retailers

Posted in Advertising & Product Risk Management, Environment & Natural Resources
Retailers face serious challenges in complying with their obligations under Resource Conservation and Recovery Act (“RCRA”) and other federal environmental statutes in light of the wide variety of retail products covered by EPA’s waste disposal regulations. EPA recently expressed its intent to consider future rulemaking under RCRA governing retail products unsold, returned, or removed from… Continue Reading