On February 8, 2023, a majority of commissioners of the Consumer Product Safety Commission (CPSC or Commission) voted to issue a supplemental notice of proposed rulemaking (SNPR) on the CPSC’s procedures for disclosing information to the public under Section 6(b) of the Consumer Product Safety Act (CPSA). The notice follows the publication of a briefing

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.
FTC Extends Comment Period for Green Guides Update
At the request of multiple stakeholders, the Federal Trade Commission (FTC) announced today that it is giving additional time for the public to weigh in on proposed changes to its Green Guides for the Use of Environmental Claims (Green Guides). The FTC has extended the public comment period for 60 days, now ending on April…
NetChoice Challenges Constitutionality of California Age-Appropriate Design Code Act
When the California legislature passed the California Age-Appropriate Design Code Act (CAADCA or Act) AB 2273 in September of this year, it generated considerable controversy. Companies, trade associations, and even some non-governmental organizations questioned whether the law’s broad reach was not just counterproductive and likely to invade consumer privacy, but preempted by federal law and…
FTC Starts Long-Awaited Green Guides Review
Update: The formal Federal Register notice was published on December 20, 2022, and comments are due on February 21, 2023.
On December 14, 2022, at an open meeting of the Federal Trade Commission (“FTC” or “Commission”), FTC Commissioners voted unanimously to publish a Notice in the Federal Register announcing a Request for Public Comments on…
FTC Proposes Trade Regulation Rule on Deceptive Reviews
Deceptive reviews and endorsements have been an increasing area of scrutiny by the Federal Trade Commission (FTC or Commission). In the last few years, the Commission has brought myriad complaints against companies for engaging in such practices. Last year, the FTC resurrected its long-dormant Penalty Offense Authority, warning more than 700 companies in a…
CPSC Adopts New Furniture Tip-Over Rule
On October 19, 2022, the Consumer Product Safety Commission (CPSC or Commission) approved a Final Rule imposing mandatory safety requirements for clothing storage units (CSUs) that will, according to the CPSC, “significantly change the way clothing storage units are tested and labeled” to address furniture tip-over hazards. The rulemaking has been in the works…
FTC Issues Advance Notice of Proposed Rulemaking on Commercial Surveillance and Data Security
At a press conference on August 11, 2022, the Federal Trade Commission (FTC or Commission) announced an Advance Notice of Proposed Rulemaking (ANPR), which was published, along with a fact sheet, to explore potential new rules governing what the FTC characterizes as prevalent “commercial surveillance” and “lax data security practices.” The FTC issued the…
FTC Submits COPPA Report to Congress, Extends Comment Deadline for October “Stealth Advertising” Workshop
On August 24, 2022, the Federal Trade Commission (FTC or Commission) submitted a report to the Congressional Committees on Appropriations detailing current resources and personnel dedicated to COPPA enforcement, the number of COPPA violation investigations over the past five years, and the types of relief obtained in completed investigations. The report was submitted in response…
CPSC to Hold Workshop on Beta Testing of eFiling Compliance Data for Imported Consumer Products
In a notice published in the Federal Register on August 8, 2022, U.S. Consumer Product Safety Commission (CPSC) staff announced that the CPSC will hold a workshop on October 13, 2022, to discuss CPSC’s eFiling Program and the Commission’s plans for a joint Beta Pilot Test with U.S. Customs and Border Protection (CBP) (previously…
Two Senate Recycling Bills Pass Unanimously
Two recent Senate bills show that Congress is working to improve the nation’s patchwork of recycling laws. On July 28, 2022, the Senate voted unanimously to pass The Recycling Infrastructure and Accessibility Act of 2022 (RIAA) and The Recycling and Composting Accountability Act (RCAA). The first of these directs the U.S. Environmental Protection Agency (EPA)…