This month, the California Department of Resources Recycling and Recovery (CalRecycle) is soliciting public feedback on two rulemakings related to extended producer responsibility (EPR) programs that apply to covered battery-embedded products (along with other types of electronics) and loose batteries. Comments on CalRecycle’s draft regulations to implement SB 1215, which revised the state’s Covered

Sheila Millar
Sheila A. Millar is a partner at Keller and Heckman LLP, where she represents businesses and trade associations on a variety of public policy and regulatory issues, including privacy, data security, cybersecurity and advertising matters, as well as product safety issues. She has been involved in a variety of audit and compliance projects, including, among other issues, privacy and data security audits, and is experienced in providing crisis management legal support to a variety of national and international companies and associations.
Ms. Millar is a frequent speaker on regulatory and public policy matters, and has authored many articles. Ms. Millar is one of the vice chairs of the International Chamber of Commerce (ICC) Marketing and Advertising Commission, and chair of its Working Group on Sustainability, where she spearheaded the development of the ICC Framework Guides on Environmental Marketing Claims.
Ms. Millar is AV® PreeminentTM Rated by Martindale-Hubbell and for the eigth consecutive year was selected by her peers for inclusion in The Best Lawyers in America® 2018 for her work in practicing Advertising Law. She has also received the distinguished honor of Advertising Law "Lawyer of the Year" 2014 in Washington, DC by Best Lawyers®, and was awarded Advertising and Marketing Lawyer of the Year USA by Finance Monthly for their Finance Monthly Global Awards 2017.
KOSA is Back and Still Controversial
On May 14, 2025, the Kids Online Safety Act (KOSA), SB 1748, was reintroduced for the fourth time by original sponsor Marsha Blackburn (R-TN), joined by Senators Richard Blumenthal (D-CT), John Thune (R-SD), and Chuck Schumer (D-NY). First introduced in 2022, and then again in 2023 and 2024, KOSA imposes a duty of care on…
FTC Delays Enforcement of Click-to-Cancel Rule
Last November, the Federal Trade Commission (FTC or Commission) published its final click-to-cancel rule (the Rule), which requires sellers to make it as easy for consumers to cancel their enrollment into a service or goods plan as it was to sign up. As we discussed previously, the Rule prohibits sellers from misrepresenting any material…
CPSC Withdraws Lithium-Ion Battery Rulemaking
Less than two weeks after the Consumer Product Safety Commission (CPSC or Commission) voted 3-2 to move ahead with a Notice of Proposed Rulemaking (NPR) for a new safety standard for lithium-ion batteries used in e-mobility devices, in a not unexpected move, the Commission, now consisting of two Republicans, voted to withdraw the NPR. But…
CPSC Advances Lithium-Ion Battery Safety Standard for E-Mobility Devices
In a 3-2 party-line vote, the three Democratic commissioners at the Consumer Product Safety Commission (CPSC or Commission) voted on April 30, 2025, to move forward with a Notice of Proposed Rulemaking (NPR) for a new safety standard for e-mobility products using lithium-ion batteries, such as hoverboards, e-bikes, and e-scooters. A proposal by Acting Chairman…
FTC Finalizes Updates to Children’s Privacy Rule…Again
After a period of regulatory review under Chairman Andrew Ferguson, on Tuesday, April 22, 2025, the U.S. Federal Trade Commission (FTC) published amendments to the Children’s Online Privacy Protection Act (COPPA) Rule (COPPA Rule or the Rule), which was last updated in 2013. As we reported earlier this year, the FTC finalized its most recent…
FTC Calls for Public Feedback on Tech Censorship
The Federal Trade Commission (FTC or Commission) is asking members of the public to weigh in on whether tech platforms restricted or blocked their access because of content they posted on those platforms. The FTC issued a Request for Information (RFI) on February 20, 2025, to “better understand how technology platforms deny or degrade (such…
Passing the Buck on Recycling: Textiles as a Case Study of State EPR Laws, Published by WLF
Keller and Heckman Partner Sheila Millar and Counsel Antonia Stamenova-Dancheva authored the Washington Legal Foundation (WLF) Working Paper, “Passing the Buck on Recycling: Textiles as a Case Study of State EPR Laws.” The article reviews international and domestic concerns over textile waste, provides an overview of California’s Responsible Textile Recovery Act of 2024 (RTRA), and…
Privacy and Advertising Year in Review 2024: Will Kids and Teens Remain a Focus in 2025?
A new year. A new administration in Washington. While protecting kids and teens is likely to remain an issue that drives legislation, litigation, and policy discussions in 2025, issuance of 1,000 Executive Orders on day one of the Trump Administration may result in new or changed priorities and some delay in the effective date of…
Updated COPPA Rule on Hold?
As we recently reported, the Federal Trade Commission (FTC or Commission) finalized updates to the Children’s Online Privacy Protection Rule (COPPA Final Rule or Rule) on January 16, 2025, and the updates were due to take effect 60 days after publication in the Federal Register. However, an Executive Order issued by President Trump on…