NCL condemns Trump’s efforts to undermine CFPB’s ability to protect consumers 

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Media Contact: Lisa McDonald, Vice President of Communications, 202-207-2829

Washington, DC — The National Consumers League (NCL) strongly condemns the Trump Administration’s reported plans to have the Office of Management and Budget (OMB) or the Department of Treasury supervise CFPB operations. Such steps would undermine critical consumer and small business protections, cost hardworking Americans their jobs, and leave millions of consumers more vulnerable to predatory financial practices.

The CFPB was established as an independent agency to protect consumers from deceptive practices in the financial marketplace, and it has been a vital safeguard for American consumers since its creation in 2011. Since that time, the agency has recovered $19.7 billion for consumers.

“We are deeply concerned about the potential consequences of these actions,” said John Breyault, Vice President of Public Policy. “It is crucial that we keep the CFPB strong, independent, and fully operational in order to protect consumers nationwide from financial harm.”

Congress explicitly designed the CFPB to be an independent agency within the Federal Reserve System. Executive actions to place the agency under OMB or Treasury supervision are likely illegal. NCL believes that undermining the CFPB’s independent structure would take the country backward, eroding the essential consumer protections that have helped combat abusive practices in the financial industry, such as payday lending, illegal credit card fees, deceptive loans,  and mortgages, and more.

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About the National Consumers League (NCL)

The National Consumers League, founded in 1899, is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit www.nclnet.org.

NCL calls for immediate action on aviation safety following tragic Washington, DC plane crash

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Media Contact: Lisa McDonald, Vice President of Communications, 202-207-2829

Washington, DC — National Consumers League (NCL) is heartbroken by the tragic crash of American Airlines Flight 5342 in Washington, DC. We extend our deepest condolences to the families and loved ones of the 64 passengers and crew members who perished, as well as the three service member aboard the Army Black Hawk helicopter. This tragedy is a stark reminder that safety must be the #1, #2, and #3 priority, above all else, in our nation’s aviation system.

This crash follows a long-standing and growing concern about the dangers of overcrowded airspace, particularly at Ronald Reagan Washington National Airport (DCA), home to the busiest runway in the nation. The airspace around DCA, heavily congested with both passenger planes and military aircraft on security patrols, has seen a series of near-misses and incidents. Experts and lawmakers have repeatedly warned about the risks, citing a series of near-misses and incidents—including a recent incident where a catastrophic runway collision was narrowly avoided. Despite these red flags, Congress continues to push for increased flights in this already overburdened airspace.

This tragedy must serve as a wake-up call for the urgent action. It is critical to reevaluate flight patterns, air traffic control resources, and safety protocols. To restore passenger trust in air travel, we need a thorough, transparent investigation into this tragedy, along with a concrete plan to address the underlying issues of congestion and air traffic control shortages.

“While investigations will seek to determine the precise cause of this crash, one thing is clear: we must not wait for another catastrophe to make air travel safer,” says John Breyault, Vice President of Public Policy, which has been pushing for passenger safety and updated evacuation policies. Breyault served on the Aviation Consumer Protection Advisory Committee from 2021-2024.

When speaking to the media President Trump has recklessly blamed diversity, equity, and inclusion hires —along with the last two Democratic presidents —for the crash. This politically motivated finger-pointing isn’t just misleading; it’s a blatant attempt to distract from the real issues. NCL urges lawmakers, regulators, and the aviation industry to come together and take immediate steps to enhance safety in our nation’s airspace. It is time to prioritize reforms that protect the lives of passengers and restore confidence in air travel.

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About the National Consumers League (NCL)

The National Consumers League, founded in 1899, is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit www.nclnet.org.

A win for human rights: DC mayor’s signature is a major step in banning child marriage

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Media Contact: Lisa McDonald, Vice President of Communications, 202- 207-2829

Washington, DC – The National Consumers League (NCL) applauds Washington, DC Mayor Muriel Bowser for signing the Child Marriage Prohibition Amendment Act of 2024 into law. This important legislation prohibits child marriages in the District of Columbia, ensuring the protection of minors from this harmful practice. The bill will now undergo 30 days of congressional review. If approved by Congress, the District of Columbia will join the 13 U.S. states and two U.S. territories that have already banned child marriage.

As a longstanding advocate for the basic human rights of girls and women worldwide, NCL expresses deep gratitude to Mayor Bowser and Councilmember Pinto for their leadership in addressing this critical issue.

“We’re delighted that Washington, DC is taking a significant stand against child marriage,” said Reid Maki, Director of Child Labor Advocacy at the National Consumers League and Coordinator of the Child Labor Coalition. “This legislation, in a city that has unfortunately seen an increase in child marriages, sets a powerful example for other cities, states, and nations to follow. Ending this practice will protect young girls from the many negative health and social consequences that early marriage brings.”

The decision to protect children from the harmful practice of early marriage is not just a local victory but a beacon of hope for girls around the world. Recent global developments, such as Iraq’s troubling decision to reduce the legal marriage age to just 9, emphasize the urgency of upholding basic human rights for girls and women everywhere.

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About the National Consumers League (NCL)
Founded in 1899, the National Consumers League (NCL) is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit nclnet.org.

Additional Resources

Forced Marriage Still a Reality in the U.S. (Blog)

Child Marriage Survivors Share Their Stories (Podcast)

Child and Forced Marriage Put the “Lock” in Wedlock (Podcast)

NCL supports click-to-cancel legislation in Maryland Senate

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January 21, 2025

Media Contact: Lisa McDonald, Vice President of Communications, (202)- 207-2829

Washington, DC – Today, NCL submitted testimony in support of SB49 before a Thursday hearing in the Maryland Senate Finance Committee.

 

January 21, 2025

The Honorable Pamela Beidle, Chair
Senate Finance Committee
Maryland General Assembly
3 East Miller Senate Office Building
Annapolis, MD 21401

RE: NCL support for SB 49 (Consumer Protection-Automatic Renewals)

Dear Chair Beidle,

On behalf of the National Consumers League (NCL), the nation’s oldest consumer advocacy organization, I write to express our strong support for SB 49 (cross-filed with HB 107), a bill introduced by Senator Gile that would promote fairness in the marketplace for automatically renewing subscription contracts.^1 As an organization that has long championed consumer rights and the protection of vulnerable populations from unfair, abusive, and deceptive trade practices, we are pleased to see Maryland considering such important legislation. We urge the committee to favorably report the measure with amendments to strengthen the legislation even further.

The average consumer pays two-and-a-half times what they originally estimated on monthly subscriptions.^2 When an individual attempts to cancel an automatic renewal, they often encounter burdensome cancellation processes. One survey found that more than half of respondents
reported an average of three months to cancel unwanted recurring payments.^3 That same study discovered that 71% of individuals lost more than $600 a year in unwanted payments.

NCL has been an active supporter of auto-renewal protections in other jurisdictions, including at the Council of the District of Columbia^4 and the Federal Trade Commission,^5 where rules set clear guidelines for both the provision and cancellation of automatically renewing subscription contracts. These measures were designed to enhance transparency, prevent deceptive practices, and ensure that consumers are able to easily cancel such subscriptions without unnecessary obstacles or undue financial burdens. We believe that SB 49, which reflects many of these same principles, is a step in the right direction toward safeguarding Maryland consumers from exploitation through automatic renewal clauses that can trap them into paying for services they no longer wish to receive or did not realize they signed up for in the first place.

While the Federal Trade Commission has finalized its click-to-cancel rule to take effect nationwide,^6 the future of this federal regulation is uncertain as a new presidential administration and new majorities in Congress have the means to undo the critical consumer protection. Regardless of the federal regulation’s status, Maryland has the opportunity to enact even stronger protections for its citizens through SB 49.

Compared to the federal rule, Senator Gile’s legislation goes further in protecting Marylanders by requiring sellers to provide an annual notice to consumers enrolled in an autorenewal plan, clearly reminding them of the terms of the plan and the cancellation methods available. Additionally, SB 49 includes safeguards against free trial conversion traps, a provision that is absent in the federal regulation.

There are however a few improvements that the committee should implement to better protect Maryland consumers.

First, require sellers to obtain a separate consent solely for the automatically renewing piece of the product, apart from any other transaction. Consumers too often believe they are purchasing a product without knowing that they are signing up for a subscription. While the clear and conspicuous disclosures proposed in SB 49 will go a long way in reducing this unfair, abusive, and deceptive trade practice, requiring separate consent for the subscription should significantly reduce any remaining confusion.

Second, require sellers to provide a notice to consumers before each automatic and recurring payment. While the annual notice in the bill is commendable, providing the same reminder (including the terms of the plan, the amount to be charged, and the cancellation methods) before each recurring payment—whether they be annually, monthly, or similarly regular basis—would greatly lessen consumer harm.

Third, prohibit sellers from obtaining a consumer’s credit card information to begin a free trial. Too many dishonest businesses enroll consumers in free trial conversion traps, using pre-given credit card information and hidden consent for the conversion to a paid subscription. SB 49’s notice requirement before conversion should dissuade this practice, prohibiting sellers from requiring consumers to provide their credit card information to begin a free trial would eliminate this unfair, abusive, and deceptive practice entirely.

Lastly, remove the deferral to federal regulation in subsection E (lines 20 through 23 on page 5). SB 49 in its current form already includes a number of additional safeguards missing in the federal regulation. Allowing covered entities to escape their obligations under Maryland law as long as they adhere to the lesser requirements in the federal regulations would be unnecessarily self-limiting. The Federal Trade Commission itself included a deferral to the states in its regulation, stating in 16 CFR § 425.7

(a) In general. This part shall not be construed as superseding, altering, or affecting any State statute, regulation, order, or interpretation relating to negative option
requirements, except to the extent it is inconsistent with the provisions of this part, and then only to the extent of the inconsistency.

(b) Greater protection under State law. For purposes of this section, a State statute,
regulation, order, or interpretation is not inconsistent with the provisions of this part if it affords any consumer greater protection than provided under this part.^7

NCL applauds Senator Giles for her leadership on this issue and appreciates the committee’s work to protect Maryland consumers. By enacting SB 49, Maryland would join a growing list of states and localities working to curb the negative effects of automatic renewal schemes and ensure that businesses are held accountable for their marketing and contract practices. NCL supports SB 49 and urges the committee to strengthen the bill even further before favorably
reporting the measure.

Should you or your colleagues have any questions, please do not hesitate to contact me at your convenience.

 

Sincerely,

Eden Iscil
Senior Public Policy Manager
National Consumers League
edeni@nclnet.org

cc: The Honorable Antonio Hayes, Vice Chair, Senate Finance Committee
The Honorable Dawn Gile
The Honorable Andrew Prusk

 

1 “Consumer Protection – Automatic Renewals,” Maryland General Assembly, accessed January 21, 2025. https://mgaleg.maryland.gov/mgawebsite/Legislation/Details/sb0049
2 “Subscription Service Statistics and Costs,” C+R Research, May 18, 2022. https://www.crresearch.com/blog/subscription-service-statistics-and-costs/
3 “Survey from Chase Reveals That Two-Thirds of Consumers Have Forgotten About At Least One Recurring Payment In The Last year,” Chase, April 1, 2021. https://media.chase.com/news/survey-from-chase-reveals
4 “D.C. Law 22-235. Structured Settlements and Automatic Renewal Protections Act of 2018,” Council of the District of Columbia, March 13, 2019. https://code.dccouncil.gov/us/dc/council/laws/22-235
5 “NCL welcomes FTC’s click-to-cancel rule,” National Consumers League, October 17, 2024. https://nclnet.org/ncl-welcomes-ftcs-click-to-cancel-rule/ 
6 “Federal Trade Commission Announces Final ‘Click-to-Cancel’ Rule Making It Easier for Consumers to End Recurring Subscriptions and Memberships,” Federal Trade Commission, October 16, 2024. https://www.ftc.gov/news-events/news/press-releases/2024/10/federal-trade-commission-announces-final-click-cancel-rule-making-it-easier-consumers-end-recurring 
7 “Part 425—Rule Concerning Recurring Subscriptions and Other Negative Option Programs,” Code of Federal Regulations, January 16, 2025. https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-425

 

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About the National Consumers League (NCL)
The National Consumers League, founded in 1899, is America’s pioneer consumer organization.  Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad.  For more information, visit nclnet.org.

Protecting American Consumers: A Conversation with Sally Greenberg, CEO on Coffee with Ken

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 Media Contact: Lisa McDonald, Vice President of Communications, 202-207-2829

Washington, DC –Sally Greenberg, CEO of the National Consumer League (NCL), was recently the featured guest on Ken Biberaj’s Coffee with Ken. On Protecting American Consumers: A Conversation with Sally Greenberg, they discussed her extensive background in consumer advocacy, the history and monumental victories of NCL, and NCL’s top priorities for 2025 as a new administration is on the horizon.

“Consumer protection is a bipartisan issue – whether it is about protecting your kids, safeguarding your health, preventing fraud, or addressing junk fees,” said NCL CEO Sally Greenberg. “We can all agree on the importance of these issues.”

NCL played a critical role in shaping policies like the Fair Labor Standards Act of 1938 and the Pure Food and Drugs Act of 1906, and today, Greenberg leads efforts to protect consumers in areas like fraud, airline transparency, food labeling, and alcohol labeling. Alcohol labeling continues to be a priority and has been an unmet consumer need for the last two decades. As a general matter, NCL prioritizes science-based information and it is fundamental to all NCL’s work.

Whether it is the ever-growing issue of fraud or endless junk fees, NCL is committed to bipartisan efforts to protect all consumers. How does NCL do it? “good data, good facts, relentless advocacy and working across the aisle.”

Watch the full episode here.

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About the National Consumers League (NCL)

The National Consumers League, founded in 1899, is America’s pioneer consumer organization.  Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad.  For more information, visit nclnet.org

NCL urges timely action to require standardized alcohol content, nutrition and allergen labeling on beer, wine, and distilled spirits products

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Media Contact: Lisa McDonald, Vice President of Communications, (202) 207-2829

Washington, DC – Having pressed the Treasury Department’s Alcohol and Tobacco Tax and Trade Bureau (TTB) for over two decades to require alcohol labeling on beer, wine, and distilled spirits products, the National Consumers League today called for an expedited process to finalize and implement a new TTB rulemaking that will give consumers the same important facts about the content of an alcoholic beverage that is now is readily available on all other beverages, food products, and dietary supplements.

TTB’s rulemaking, published in the Federal Register on January 17, 2025, includes two proposed rules, both of which are necessary for the 62 percent of adult Americans who drink to make responsible drinking decisions. The first rule would require a standardized label, similar to the Nutrition Facts label commonplace on food and beverage products, that tells consumers the percentage of alcohol per volume, the alcohol content in fluid ounces, and the calories, carbohydrates, fat, and protein per serving. The second rule requires listing allergens in the alcoholic beverage, which is important to the 33 million people in the US who have at least one food allergy. Currently, manufacturers of TTB-regulated beer, wine, and distilled spirits are not required to declare the presence of major allergens which are used as ingredients or processing agents.

Noting that overconsumption of alcohol is a costly public health problem that has become much worse in recent years, as alcohol-related deaths have risen substantially, NCL stated that the proposed labeling rules are long overdue to protect the health and safety of the public. According to the latest estimates, alcohol accounts for 30 percent of all traffic crash fatalities in the US, is a source of empty calories that contribute to obesity, and excessive drinking increases the risk of liver disease, hypertension, cardiovascular disease, alcohol use disorders, certain cancers, and severe injuries.

“While NCL is pleased that TTB published these labeling rules, the agency has a long history of asking for public comments, holding listening sessions, and publishing proposed alcohol labeling rules that are never finalized,” said Sally Greenberg, NCL’s CEO. “This is why we are pressing for an expedited process, because the health and safety of the public is at stake.”

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About the National Consumers League (NCL)

The National Consumers League, founded in 1899, is America’s pioneer consumer organization.  Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad.  For more information, visit nclnet.org.

NCL celebrates landmark progress in ticket fee reform 

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December 18, 2024

Contact: National Consumers League – Lisa McDonald, lisam@nclnet.org, 202-207-2829

Washington, DC – The National Consumers League (NCL) applauded Congress for including the bipartisan TICKET Act (S. 1303/H.R. 3950) in the year-end funding legislation. This marks a significant milestone in NCL’s decade-long fight to secure stronger consumer protections for live event fans. NCL looks forward to working with Congress and President Biden to see these landmark reforms signed into law.

The TICKET Act, backed by more than a dozen consumer and fan advocacy organizations and live event industry stakeholders, introduces key regulations to protect consumers, including:

  • Requiring all-in pricing to eliminate hidden fees.
  • Banning speculative ticketing and deceptive marketing practices.
  • Guaranteeing refunds for canceled or postponed events.
  • Mandating an FTC study on BOTS Act enforcement.

The following statement is attributable to John Breyault, NCL Vice President of Public Policy, Telecommunications, and Fraud:

“Live event fans are one step closer to saying goodbye to hidden ticket fees that have frustrated consumers for decades. The TICKET Act will also end deceptive speculative ticket sales and ensure fans get their money back when events are canceled or postponed. These long-overdue reforms are a victory for consumers, and we thank congressional leaders for their commitment to making this law a reality.

Special thanks go to Senators Cantwell, Cruz, Klobuchar, and Schumer and Representatives McMorris Rodgers, Pallone, Schakowsky, Bilirakis, and the co-sponsors of S. 1303/H.R. 3950, whose dedication made this bipartisan consumer protection victory possible.”

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NCL hails FTC ban on hidden junk fees in ticketing and lodging

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December 17, 2024

Media contact: National Consumers League – Lisa McDonald, lisam@nclnet.org, 202-207-2829

Washington, DC – Today, the FTC announced its final rule banning hidden junk fees in live-event ticketing and short-term lodging. NCL has long advocated for such a ban at the federal level and applauds the Commission for enacting this critical consumer protection regulation.

“Sellers in these industries can no longer lie to consumers to make a buck. The FTC’s final rule is a common-sense policy that will make the ticketing and lodging marketplaces fairer for everyone involved,” said NCL Vice President John Breyault. “The price that’s advertised is the price that you should pay.”

This single rule by the FTC will result in billions of dollars in savings for consumers. A non-partisan federal study of the ticketing industry found that primary and secondary ticket sellers charged fees averaging 27% and 31%, respectively, of the ticket’s price. Regarding lodging, the Council of Economic Advisers estimated that consumers lose $3.3 billion annually to hotel junk fees.

Further reading:

2024 public comments of the National Consumers League and 51 other organizations supporting the FTC’s proposed rule to ban junk fees

2024 public comments of the Break Up Ticketmaster Coalition (NCL and 14 other organizations) supporting the FTC’s proposed rule

2023 testimony of NCL’s CEO before the United States Senate on the need to prohibit junk fees

2023 public comments of the National Consumers League and 41 other organizations supporting the FTC’s advanced notice of proposed rulemaking on junk fees

2022 public comments of the National Consumers League supporting a petition for rulemaking to ban drip pricing, which resulted in this final rule

2018 public comments of the National Consumers League and the Sports Fans Coalition urging FTC intervention in the ticketing industry

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About the National Consumers League (NCL) 

The National Consumers League, founded in 1899, is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit www.nclnet.org.

NCL calls on Congress to include TICKET Act in continuing resolution

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December 16, 2024

National Consumers League Calls on Congress to Include TICKET Act in Continuing Resolution

Contact: National Consumers League – Lisa McDonald, lisam@nclnet.org, 202-207-2829

Washington, DC – The National Consumers League (NCL), America’s oldest consumer and worker advocacy organization, is urging Congress to include the bipartisan TICKET Act (H.R. 3950) in any Continuing Resolution (CR) passed this session. The TICKET Act represents the most significant live event ticketing reform in nearly a decade, addressing key concerns in the live event marketplace for all stakeholders.

Key provisions of the TICKET Act include:

  • Banning hidden fees through all-in pricing requirements.
  • Prohibiting speculative ticketing and other deceptive marketing practices.
  • Requiring refunds for canceled and postponed events.
  • Commissioning an FTC study on enforcement of the BOTS Act.

Earlier this year, the TICKET Act passed the House with overwhelming bipartisan support (388–24) and gained endorsements from a broad coalition of stakeholders, including the, Consumer Reports, Artist Rights Alliance, Recording Academy, Live Nation/Ticketmaster (LNE), Coalition for Ticket Fairness, Vivid Seats, StubHub, and the National Independent Venue Association and other consumer groups.

Despite previously supporting the bill, the Fix the Tix Coalition—has backed away from the bill. We think that is misguided.

“The TICKET Act is a hard-fought compromise and, we believe, Congress’ best chance to deliver meaningful reforms that benefit fans, venues, and artists as early as next summer’s concert season,” said John Breyault, NCL’s Vice President of Public Policy, Telecommunications, and Fraud. “We are disappointed that groups that had previously supported the bill have reversed themselves, though the bill has not significantly changed since they originally endorsed it. We are concerned that Ticketmaster/Live Nation, which owns primary and secondary ticketing platforms, manages hundreds of artists and owns, controls, or has exclusive contracts with hundreds of venues, may be exerting undue influence at the expense of consumers. Congress should resist special interests, and stand up for consumers by including this package of positive reforms in the CR.”

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Saving kids’ lives through safer vehicles

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Virtually every safety feature in automobiles, even those we take for granted, like seat belts and airbags, became standard equipment only after overcoming intense resistance. The technologies that have made cars much safer for both passengers and pedestrians have come about because of the commitment, determination, and resourcefulness of those who refuse to surrender in the fight for positive change.

That’s why I am so grateful for the partnership of Sally Greenberg and the National Consumers League (NCL). The work they have done and continue to do is saving countless lives.

In the 1980s, healthcare professionals were publishing papers on the number of people, predominantly small children, who were being killed or injured by cars backing out of driveways or parking spots. A 1993 report from the National Highway Traffic Safety Administration (NHTSA) found that as many as 200 pedestrians, mostly children, were being killed each year by backing out collisions. At least 50 children every week were being backed over by vehicles.

My organization, Kids and Car Safety, compiled data on the problem and concluded that the only solution would be to mandate a rear visibility standard—cameras that would allow the driver to see what was behind the car, particularly a small child who could not be seen through the rearview mirror or rear window. The regulators were not acting, so we began working with Congress on legislation to require a rear visibility standard allowing drivers to see behind them when backing up. After all, you cannot avoid hitting something or someone you cannot see.

That’s when I teamed up with Sally Greenberg, then with Consumers Union. We began a battle that would take years but was so very necessary to prevent more families from suffering avoidable tragedies. We matched our research and our firsthand witness testimonies against the arguments that rear backup cameras would add too much to the cost of cars and that drivers wouldn’t use them. We argued that they shouldn’t only be offered as an optional feature in luxury cars.

Sally and Consumers Union, along with Kids and Car Safety and NCL, tirelessly insisted that safety could not be offered only to those who could afford it.

Finally, in 2014, a new rule was issued and took effect in 2018, mandating that all vehicles sold or leased in the United States, no matter where they were manufactured, be equipped with a rear backup camera. Today, they are thought to be as essential as seat belts, airbags, side impact protection, and electronic stability control—features that no vehicle should ever be without. And it happened because of advocates like Sally Greenberg and others who simply wouldn’t back down to the powerful, well-financed opposition.

There is more to be done to make cars safer for drivers and their families. On average, about 40 children die annually in hot cars. Often, these are infants and toddlers in rear- facing car seats, and the driver, looking in the rearview mirror, can’t tell if the seat is occupied or not.

We’re pleased to have NCL’s powerful voice engaged in yet another effort to use effective technologies to save lives. Occupant detection systems can distinguish between living beings and inanimate objects in the vehicle and can alert the driver that a child is unattended in the vehicle. This system will save lives, as NCL has compellingly pointed out. There is resistance to making occupant detection systems a mandatory feature in new cars. There always is. Yet, we were successful in adding a lifesaving traffic safety provision designed to prevent hot car fatalities, in the Infrastructure Investment and Jobs Act (IIJA).

Kids and Car Safety and NCL have a solid track record of collaborating on these issues. When lives, health, and safety are at stake, I wouldn’t bet against us.

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Janette Fennell is the Founder and President of Kids and Car Safety, a national nonprofit organization dedicated to preventing injury and death to children and animals in and around motor vehicles.