Connecticut Attorney General William Tong sent a letter to Sephora regarding the marketing of anti-aging skincare products with harmful ingredients like retinol and acids to children and teens on social media. The AG seeks information on product placements in searches for kids and warning practices, cautioning parents about potential skin harm from these products.
In-house legal teams should review all agreements governing marketing, sales, and platform operations, including influencer marketing agreements, website terms of use, vendor agreements with brands (e.g., Drunk Elephant, Glow Recipe), and any data processing agreements if customer data is involved. Specific clauses to scrutinize are those related to marketing compliance, target audience restrictions, age-gating mechanisms, product warning and disclaimer obligations, and control over search result algorithms and product placements. Given the AG's concern over products appearing in searches for 'kids' and 'gifts for children,' contracts may need amendments to mandate stricter age verification, require prominent warnings about ingredients like retinol and acids for young users, restrict product categorization and search indexing for minor audiences, and impose obligations on influencers to include safety disclaimers when promoting such products to younger demographics.
Entity
Sephora
Industry
RetailOfficial Press Release
https://portal.ct.gov/ag/press-releases/2024-press-releases/attorney-general-tong-cautions-parents-regarding-anti-aging-skincare
sephora usa inc inquiry letter112524.pdf?rev=00d5d4e2d528481
https://portal.ct.gov/-/media/ag/press_releases/2024/sephora-usa-inc-inquiry-letter112524.pdf?rev=00d5d4e2d5284811b6cb15fb6f77f3bb&hash=588DD9C5BED120D3E887339C75E9F0C2
Connecticut Attorney General Enforcement Page
https://portal.ct.gov/AG/Privacy/Privacy-Resources
Connecticut Attorney General William Tong announced a settlement with beauty retailer Sephora resolving an investigation into the company’s marketing of anti-aging skincare products containing active ingredients like retinol to children under 13. Sephora agreed to adopt enforceable safeguards including requiring suppliers to provide age suitability warnings, disclosing those warnings on product pages, training employees to advise young customers, and maintaining a public resource on age-appropriate products. No monetary penalty was imposed.
Connecticut Attorney General William Tong joined a coalition of states and local governments in filing suit against NHTSA over its rule weakening fuel economy standards for new passenger cars and light trucks. The lawsuit alleges the rule violates the agency’s statutory mandate and the Administrative Procedure Act; no penalty or final remedy is reported.
Connecticut Attorney General William Tong joined a multistate coalition suing the EPA over its repeal of greenhouse gas pollution limits for power plants and separately filed a notice of intent to sue over regulation of existing gas plants. The coalition asks the court to overturn the repeal and restore the protections; the release reports no monetary penalty or final order.
$400.0M
Connecticut Attorney General William Tong announced a $400 million settlement with Sandoz Inc. and Fougera Pharmaceuticals Inc. resolving allegations that the generic drug manufacturers conspired to inflate prices, limit competition, and restrain trade. The settlement includes consumer restitution and injunctive reforms; court approval was being sought.
Connecticut Attorney General William Tong joined a coalition of 21 attorneys general in submitting a comment letter opposing a DHS rule that allows certain affirmative asylum applications to be referred to removal proceedings without an asylum officer interview. The coalition argues the rule violates federal law and harms asylum seekers, including unaccompanied children; this was a policy opposition letter, not a privacy enforcement action.
Connecticut and Massachusetts co-led a coalition protest urging FERC to reject the proposed NextEra Energy-Dominion Energy merger. The coalition argued that the merger could increase market power and threaten energy affordability, reliability, and competition; the release does not report a final enforcement decision or penalty.