Skip to main content

Scott A. Cohn

Senior Regulatory Consulting Attorney
New York, NY
Scott Cohn, Senior Regulatory Consulting Attorney at Arent Fox LLP

Scott A. Cohn

Senior Regulatory Consulting Attorney
New York, NY

Scott Cohn has practiced law for more than 28 years in the area of regulatory compliance, with an emphasis on product safety and compliance, product labeling, and advertising and regulation of imported goods.

In the area of product safety and compliance, as regulated by the Consumer Product Safety Commission (CPSC), Food and Drug Administration (FDA) and other federal and state agencies, Scott has experience with the following:

  • Product Safety Evaluations, including Laboratory Testing and Failure Analyses
  • Hazard/Defect Reporting (Section 15 and 37)
  • Consumer Product Safety Improvement Act (CPSIA)
  • Recalls
  • CPSC, investigations, and penalties
  • Flammability of apparel and children’s sleepwear, including exemptions for tight-fitting sleepwear
  • Children’s products, including toys and games; small parts, sharp edges, heavy metals, lead content (including Proposition 65 in California), toxicity and contamination, etc.
  • Drawstring restrictions on apparel
  • Household products: candles, lighters, mattresses, cookware, small electronics, etc.
  • Furniture products: cribs, chairs, stools, upholstered products, etc.
  • Medical devices, cosmetics, and OTC remedies
  • Internal compliance reviews and manuals, and development of quality assurance procedures and programs

Scott’s practice also involves product labeling and advertising, as regulated by the Federal Trade Commission (FTC) and other federal and state agencies. In this area he has experience with the following:

  • Internet and Catalog Disclosures and Mail Order Rules
  • Advertising Substantiation
  • Textile, Apparel, Footwear and Luggage labeling
  • RN number filings
  • Leather labeling
  • Care labeling for apparel
  • Upholstery and Bedding labeling/tagging as required by individual states
  • "Made In USA" labeling rules for all products
  • Warranty issues
  • Privacy issues for consumers
  • Jewelry labeling and advertising
  • Organic labeling for food products under US Department of Agriculture/AMS Rules
  • Country of origin disclosures as required by Customs and FTC

Additionally, with regard to the regulation of imported goods, as enforced by the Bureau of Customs and Border Protection (CBP) and other federal and state agencies, Scott’s practice includes experience with the following:

  • Tariff Classification, Duty Rates, and Quota Restrictions applicable to all product categories
  • Structuring international trade transactions to lawfully minimize duties
  • NAFTA and other trade preference programs, such as IFTA, GSP, and AGOA
  • Informed compliance and reasonable care evaluations
  • Customs compliance audits and internal control manuals
  • Valuation of imported goods (transfer pricing, first sale, etc.)
  • Country of origin marking
  • Trademark and copyright protection and enforcement
  • Detentions, seizures, penalties, civil/criminal investigations
  • Country of origin verifications
  • Labor compliance programs
  • Restrictions on artwork and antiquities
  • Recordkeeping and record retention
  • FDA penalty enforcement actions on imports
  • Endangered species issues as enforced by Fish & Wildlife Service
  • Importation of fine art and antiquities
  • Vendor supply agreements
  • Buying agency agreements
  • Import/Export enforcement by Office of Foreign Assets Control, Bureau of Industry and Security, Department of Commerce, Department of State, Bureau of Alcohol Tobacco and Firearms, Environmental Protection Agency, etc.