Fashion Counsel with Anthony V. Lupo

Arent Fox's fashion law blog offers news, analysis, and insights for the industry from fashion attorney Anthony Lupo.

Fashion Counsel with Anthony V. Lupo

Georgia Ravitz

Georgia Ravitz, Consumer Product Safety Lawyer
Georgia Ravitz
Partner
Washington, DC
202.857.8939

Georgia Ravitz focuses on food and drug law and regulatory policy governing pharmaceuticals (including prescription drugs, generic drugs and over-the-counter drugs), biologics, cosmetics, health and beauty aids, medical devices (both PMA and 510(k) products), dietary supplements, vitamin and mineral products, food, and other consumer goods. Georgia also focuses on the laws and regulations relating to consumer products generally and those administered by the US Consumer Product Safety Commission (CPSC). She currently advises many clients on the Consumer Product Safety Improvement Act (CPSIA) and the additional requirements it imposes on manufacturers, importers, distributors, specialty retailers, and product vendors.

Georgia chairs the firm’s CPSC Committee, and is a member of the firm’s Food and Drug and Advertising groups. She formerly served on the firm’s Pro Bono Committee and remains extremely involved in pro bono matters, particularly those relating to children.

Client Work

Georgia counsels manufacturers, distributors, and retailers who manufacture and market prescription drugs, biologics, cosmetics and over-the-counter drugs, consumer products, food products, dietary supplements, and vitamin products. She has extensive experience in reviewing labeling, advertising, and packaging to ascertain compliance with applicable Food and Drug Administration (FDA) and Federal Trade Commission (FTC) regulations. Georgia also counsels clients on regulatory compliance and FDA inspections, participates in agency rulemaking and adjudicatory proceedings, responds to federal and state administrative enforcement efforts, import detention matters involving FDA and the Department of Homeland Security, and advises on civil and criminal litigation relating to FDA and related regulatory matters. Additionally, an integral component of her practice is advising companies on the level and type of product claims substantiation that will be necessary to satisfy the National Advertising Division (NAD) and the FTC. Georgia advises FDA-regulated establishments on the need to implement stock recovery and product recalls.

Georgia also works closely with manufacturers, distributors, importers, specialty retailers, and product vendors in the development of new, innovative products subject to the Federal Food, Drug, and Cosmetic Act, the Fair Packaging and Labeling Act, the Federal Hazardous Substances Act, the Consumer Product Safety Act, the CPSIA, and the various regulations enforced by the FDA and the CPSC. Over the years, Georgia has worked on many product recalls from cosmetics to electrical products to children’s products, and a wide range of other FDA regulated, personal and household products in between. She advises clients on the CPSIA and its corresponding rules, providing guidance on compliance certificates, third party testing of children’s products, tracking labels, new limits on lead and phthalates, and labeling requirements for toy and game advertisements, among other matters. Georgia actively participates in CPSC rulemakings and public meetings on the CPSIA.

Professional Activities

  • The Food and Drug Law Institute
  • Association of Food and Drug Officials
  • Lawyers for Children America

Publications, Presentations and Recognitions

In addition to giving speeches on FDA/FTC/CPSC product regulation, Georgia is a regular contributor on FDA and FTC cosmetics and personal care products issues to Happi Magazine, a well-known publication for the household, chemical, and personal products industry. Some of the articles Georgia has written include “Here’s a Better Way To Substantiate Claims,” “Will FDA Put the Heat on Salon Suppliers?” and “Should Your AHA Cream Carry a Warning Label?”

Additionally, Georgia was a featured speaker at ICPHSO, ABA Law Day, March 2013. Her presentation was titled "Product Labeling: Federal, State and Beyond - California's Proposition 65."

Life Beyond the Law

Much of Georgia’s life beyond the law is spent catering to the needs of her young children, as well as becoming involved with other young children who are from disadvantaged families and for whom help is desperately needed.

 

Blog Posts by Georgia Ravitz

Consumer Product Safety
alert
FTC Continues Close Scrutiny of "Made in USA" Claims

The Federal Trade Commission (FTC) has just announced that it will be closing its "Made in USA" investigation of certain Target pillow products. According to the FTC, the outer packaging of the pillow products bore an unqualified "Made in USA" claim while the packages' contents – the pillows themselves  bore a "Made in China" label claim. FTC's investigation began in response to numerous consumer complaints regarding this conflicting origin labeling. In response to the FTC’s investigation, Target agreed to remedy the problem, including removing all affected items from sale, introducing remedial packaging, and, most significantly, agreeing to undertake several longer term "process enhancements" designed to prevent future deceptive "Made in USA" claims.

These longer term enhancements include:

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Consumer Product Safety
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FTC Settlement Shows Agency Remains Focused on “Made in USA” Claims

The Federal Trade Commission has announced a proposed settlement and consent order in its investigation of a US-based water filtration company, iSpring Water Systems, concerning that company’s representations that its products are "Proudly Built in the USA," which is considered an unqualified "Made in USA" claim that the products were all or virtually all USA-made. These representations appeared on the company’s own websites, as well as those of other online retailers who sold the products. The FTC alleges that many of the company’s products were wholly imported and/or produced with significant foreign inputs, and therefore, the unqualified US-origin claims are false and misleading. While iSpring has neither admitted, nor denied, the allegations, it has agreed to drop the "Made in USA" references, and to make only qualified "Made in USA" claims which clearly and conspicuously identify the extent to which foreign parts, ingredients or processing are utilized.

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Consumer Product Safety
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FDA Issues Draft Guidance on Lead Levels in Cosmetics
The US Food and Drug Administration recently issued draft guidance establishing an upper limit for lead levels in externally applied cosmetics of 10 parts per million (ppm) of lead. FDA’s upper limit lead restriction applies to lip products, such as lipsticks, lip glosses, and lip liners, and to other externally applied cosmetics, such as eye shadows, blushes, compact powders, shampoos, and body lotions. FDA intends the draft guidance to educate new manufacturers entering the marketplace, as well as encourage existing manufacturers to continue to follow or improve on voluntary good manufacturing practices that limit trace amounts of lead as an impurity.

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