Sally Greenberg presented product safety keynote address at ICPHSO annual conference

Sally Greenberg, the National Consumers League (NCL) CEO, presented the following product safety principles on February 19, 2025, as a keynote speaker at the International Consumer Product Health and Safety Organization (ICPHSO) 2025 Annual Meeting and Training Symposium

 

Keynote Address to the ICPHSO 

Orlando, Florida 

800 attendees  

 

Good afternoon to everyone. It’s great to be here at this wonderful conference at what is undoubtedly one of the most challenging times for product safety.   I also want to introduce our newest NCL employee, Daniel Greene, who is fresh off Capitol Hill and has worked on product safety issues as a committee staffer and staffer for members of consumer protection committees. We’re so lucky to have Daniel joining our team.  

I’m especially glad to be helping ICPSHO get back to your roots. You haven’t had anyone this short speaking at this podium since Ann Brown was Chairman of CPSC back in the 1990s.  

During Chairman Brown’s tenure, I met some of the heroic people who put the CPSC on the map, including your CEO Mark Schoem, his brother Alan Schoem, and Pam Gilbert, my close colleague and a member of my Board. Pam served as Executive Director of CPSC during Chairman Brown’s entire tenure.  

We are gathered in this room even as we approach issues with many different perspectives, but I like to believe we’re here because we all care about making products safer.  Companies have much to do with the ecosystem that has enabled far safer products for consumers – the voluntary standard on baby walkers and the fact that hair dryers don’t electrocute people anymore are all because of industry initiatives. We very much welcome the relationships we’ve built with Amazon, Proctor and Gamble, and so many others here today. The system works best when we all have a common goal of ensuring safer products.   

I want to share some stories from my 3 decades of work as a consumer advocate. I was hired in 1998 in the DC office of Consumer Reports magazine, handling both auto safety and product safety.  My mentor was Dr. David Pittle, a mechanical engineer PhD serving as technical director in the Yonkers NY headquarters of Consumer Reports. David was a Commissioner at the CPSC under four Presidents. I knew next to nothing about product safety, but David and soon thereafter Bob Adler, who worked for David at CPSC and was acting CPSC chair, taught me some basic principles that guide my work today.   

Among those are:   

  1. Don’t blame consumers if there’s a pattern of injury and a lot of people, especially children, are getting injured using a product.  The problem is likely with the product, not the people.  
  2. It’s not misuse when people act in utterly human ways or surprise, surprise, fail to follow complex, unreasonable instructions.  
  3. If there’s technology to redesign a product to prevent injury and that technology can be adopted for a reasonable cost, it should be done, either by the manufacturer or, if they won’t act, through a required safety standard.  
  4. Everyone in the industry has to comply, so no one in the industry competes for business by reducing safety protections. 
  5. Safety should not be just for those who can afford to pay for it. Safety should be available and standard for all consumers.   
  6. Consumers may claim to dislike the government, but they universally believe that government agencies have reviewed every product on the store shelves and believe everything they buy has been vetted for safety.  
  7. Manufacturers and regulators, you cannot sticker over safety problems or put a warning label on an inherently unsafe product. Consumers have no problem with warning labels, but they are not a substitute for addressing inherent safety issues.  
  8. Education campaigns are not terribly effective if there’s an inherent safety problem with a product. Seat belts are a case in point.  NHTSA ran a multi-year, multi-million-dollar campaign to convince consumers to use seatbelts.  After spending millions of dollars and years on the campaign, the rate of seatbelt use rose from about 11 percent to 14 percent.  There was no meaningful change until states passed laws requiring the wearing of seat belts.  Current use is 91% — saving tens of thousands of lives.  
  9. Anyone who thinks that the market will sort out dangerous products is living in a dream world.  That is why we need the CPSC and other consumer safety organizations.  
  10. Capitalism works but not without regulation.  The most prosperous market economies also have extensive regulatory systems.  We need rules of the road to promote competition and rein in the tendency to put profits over preventing injuries to keep the public safe.    

So, onto a few stories.  

When I was hired at Consumer Reports in 1998, one crisis was brewing, and two were about to happen.  The first was that Consumer Reports magazine was being sued for rating two SUVs - an Isuzu Trooper and a Suzuki Samurai- as not acceptable because they, according to tests, are prone to rollover.  

CR had no one working in the DC office on auto safety or product safety. While our litigators prepared for trial, I was hired to work with Congress, consumer organizations, the National Highway Traffic Safety Administration, and automakers to advocate for CR’s interest – on behalf of consumers – in order to require that NHTSA test vehicles for stability.  

Well, let me tell you, it was a hard sell. I used to say I was the loneliest lobbyist in Washington. I walked the halls of Congress visiting members with folders filled with graphs, data about accidents and deaths, and diagrams describing the propensity of SUVs to roll over because of a higher center of gravity and how to test and correct for the problem.  Mostly I’d get a pat on the back and good luck even from friends. Congressman Ed Markey, who was in the House at the time, always welcomed me, but suffice it to say Newt Gingrich was Speaker of the House: They would tell me, “Good luck, Sally, getting anything pro-consumer done in this Congress. No one is interested in safety.”  That was 1998. By the way, Consumer Reports went to trial and won, except for one or two minor matters.  I should add that neither Isuzu nor Suzuki is in business today in the U.S.   

But things changed fast.  

Crisis number two, in 1999, Ford Explorers with Firestone tires were detrending while driving at high speeds.   

An investigative reporter at a Houston TV station started doing the math – hundreds of people were getting injured or killed when these SUVs lost tire treads, flipped over, and killed occupants. Panic increased exponentially because the garages in the House and Senate office buildings were filled with Ford Explorers.  

There was a feeding frenzy of Congressional hearings – and this time, Congressman Markey (now Senator from Massachusetts) called me and said Sally, let’s get the safety provisions into the bill now that Congress realizes how very important safety actually is – and we saw the very rapid passage of the TREAD Act of 2000, The Act set new regulations on tire quality and auto design. Firestone and Ford were forced to recall and redesign both tires and vehicles.  And guess what? Consumer Reports’ goal to require that NHTSA test vehicles for stability was written into the bill – showing that even lonely lobbyists sometimes win.  Once automakers knew their vehicles were going to be tested for stability, they managed to develop technology to prevent rollovers – known today as Electronic Stability Control.  That has saved thousands of lives.  Also, do you know that icon you see when one of your car tire pressure is low? That came out of the TREAD Act.  We haven’t had a tire detreading problem since.  

My next work crisis involved the CPSC. Before I tell that story, since most of us here today work with Commission so closely, I’d like to take a moment to recall the findings of the bipartisan 1968 National Commission on Product Safety – because it’s relevant to the CPSC saga I’m about to talk about.  

This is a largely forgotten but very important study because it was the precursor that led to the formation of the CPSC. Among the findings was this: “There is no justification for exposing an entire populace to risks of injury or death, which are not necessary, and which are not apparent to all. Such hazards must be controlled or limited not at the option of the producer but as a matter of right to the consumer.” 

In 1968, at the time of the Commission’s report, 20 million Americans were getting injured each year as a result of incidents connected with consumer products.  30,000 died.  110,000 were permanently disabled.  The annual cost to the nation of product-related injuries exceeded five and a half billion dollars. 

The Commission had identified a perilous race to the bottom.  Safety took a back seat to profit.  I was struck by the examples in the report:   

  • Valves that substantially reduced the risk of aerosol can explosions were not installed because industry saved three-and-a-half cents per can.  
  • Pressure tests to reduce the risk of soda bottle explosions were not performed, which saved one-fifth of one cent per bottle.   
  • Magnetic latches on refrigerators, which prevent entrapment, were not installed.    

Nearly five hundred million dollars – or two percent – of all public health expenditures were attributed to product hazards.  

The Congressional study recommended the formation of the CPSC, and Congress fulfilled the request in 1972. Richard Nixon, a Republican president, signed the bill into law.  

Before I tell you about crisis #3, I want to tell you a story that proves that humility is an important thing to experience. While I was working for Consumer Reports, the magazine sent a gift out to new subscribers that included a small flashlight. Well, the flashlight was defective. When turned on, within a matter of minutes, it overheated, and some consumers reported to us that it even caught fire. Guess what? We had to conduct a recall. And I was in charge of the recall. So, my first call was to Marc Schoem at CPSC, who is now your Executive Director. 

I had known Marc for years, but not in this context. He was by the book 100%. He insisted we follow the protocol of every other company, do a press release, admit fault, recall the flashlights, provide compensation, and warn the public. Let me just say he wasn’t warm and fuzzy. It was the right thing, and we did everything Mark told us we had to do. So, to any company that has had a recall, I feel your pain. The lesson for us was even Consumer Reports screws up from time to time; even CR can end up with a product we didn’t make but gave away with a defect. You must report it as soon as you discover the problem and work with CPSC staff and experts to get the word out to the public and take all the necessary steps. I was actually very glad to have Marc Shoem there to tell us how to do the right thing.  

Now, back to my third crisis. In 2000, President George W Bush nominated CPSC Commissioner Mary Sheila Gall to become chairman of the Commission. Consumer advocates were concerned because Commissioner Gall had a record of blaming parents when there was a pattern of injury from products that harmed children. She also repeatedly referred to the CPSC as “The Nanny State,” and when kids chewed on zippers on the seams of baby walkers and lost baby teeth, she opined that, well, they were just baby teeth.  We felt she fundamentally misunderstood the mission of the CPSC, which was not to blame consumers when there was a pattern of injury but to fix the product. Despite all this, she would have been confirmed by the Senate to chair the Commission, but the Republicans lost their majority, and her nomination failed to move to the full Senate.  

Fast forward to today, I think the 1968 Commission would be very pleased with the CPSC’s record. This small agency with a large mission has helped spur a 43 percent decline in residential fires, a 47 percent decrease in fire deaths, and a 41 percent reduction in fire injuries. Child poisoning has decreased by 80 percent.  Bicycle injuries dropped by 35 percent.  Deaths from refrigerator door entrapments and garage door incidents have been virtually eliminated.  Crib deaths have plummeted by 80 percent.  Injuries associated with baby walkers have been slashed by 88 percent. Pool and pool equipment injury rates have decreased by 55 percent.  

 We should celebrate these successes. But we cannot rest on our laurels.   

Falls, fires, poisoning, and suffocation remain persistently high, accounting for four out of five deaths.  Everyday product categories – such as stairs, ramps, beds, pillows, chairs, exercise equipment, bathtubs, and bicycles – are frequently involved. The young and the elderly are particularly vulnerable. Product safety hazards remain a present threat.   

This brings me to the very frustrating matter of table saw safety, something I’ve been working on since 2008.  Table saws cause roughly 54,000 medically treated injuries and often very gruesome injuries every year. There’s technology to make them completely safe. It has been working for 20 years in safely designed saws, but the industry has put up fierce resistance to making this technology standard on all saws, primarily for cost reasons.  They don’t want to pay to have their table saws reengineered and object to paying the inventor for his patents on the safety technology. The other thing industry members have been known to do is to get Congress to pass a law saying that the CPSC cannot work on making their products safer, which essentially bans the agency from working on gas generators or table saws, which is outrageous in my view. That is why we have a safety agency.  By the way, the inventor of safety technology started his own company, SawStop, and 250,000 of these saws are in circulation. Shop classes buy them, and anyone who cares about their fingers should absolutely invest in a safe saw because it takes only a fraction of a second to have an accident. I know because we brought many table saw victims to town and their injuries are horrific. Today, we are closer than ever to having a mandatory standard thanks to former Chairman Alex Hoehn Saric and the incredible unsung work of Engineer Caroleen Paul at CPSC. But under this new administration, it won’t happen. So sadly, table saws continue to inflict gruesome injuries every day.  

In 1994, Automotive News wrote an editorial that is my favorite of all time. It said this:  

“All safety-related devices should become standard equipment.  It’s a moral decision. When the choice becomes profit vs. lives, the decision should be simple.” I wrote a blog about it on my website.  

Should this principle apply to the table saw industry? I certainly think so. If anyone wants to know more, I’ve written about this extensively on our website, nclnet.org  

Moving on to where we are today. E-Commerce presents a huge product safety challenge. In recent years, a new pipeline of products has opened, flooding the market with dangerous and hazardous products.  I want to thank Amazon for trying to find a resolution alongside consumer advocates to find a way to prevent the sale of products that are under recall.   

E-commerce sales exceeded $1.1 trillion in 2023.  That’s over fifteen percent of total retail sales that year.  

 Consumers understandably assume that products bought online are just as safe as products bought at a store.  Far too often, that’s not the case.   

 My last several pitches are these three:  

First, funding for the chronically underfunded CPSC as e-commerce grows each year. CPSC has a massive workload with jurisdiction over roughly 15,000 product types. Despite a request for an increase, its budget was cut in 2024 to $150 million, far and away the smallest of the federal health and safety agencies.  FDA’s is 44 times that of CPSC; their increase is more than CPSC’s total request.  NHTSA has more than 7 times that of CPSC  

No agency has broader jurisdiction than CPSC. But again, in this environment, I’m not under any illusions that will happen.  

Second, 6B presents a problem unique to the CPSC. CPSC must run information disclosures past manufacturers (and private labelers) and give them 15 days’ advance notice to comment on the fairness and accuracy of information.  Then, if a firm protests, CPSC must take “reasonable steps” to determine that information release is fair and accurate.  Then, the agency must give a firm no less than 5 days’ additional notice to permit a lawsuit challenging the information release.  Now, 50 years after the enactment of 6(b), CPSC remains the only agency that operates under 6(b) restrictions.  Not FTC, OSHA, EPA, NHTSA, CFTC, or any other regulatory agency. This imposes substantial costs and delays in alerting the public to safety hazards.  When I last checked, the average time to process requests under 6(b) was roughly 4 times as long as processing non 6(b) requests—hundreds of thousands of dollars in extra costs.  

We believe that someday, in product safety heaven, section 6B will be repealed, and the CPSC will not be forced to expend extra funds it can ill afford, and consumers will be informed promptly without undue delay about product safety hazards.  

And finally, I have what I call a modest proposal. I work with other federal agencies, including the FDA. In 2007, a group of diverse stakeholders founded an entity called the Alliance for a Stronger FDA. Today, the Alliance unites a broad coalition of 150 consumer and patient groups, biomedical research advocates, health professional societies, trade groups, and many food and drug companies. The Alliance advocates for increased budget authority (BA) appropriations to support the FDA and educates policymakers, the media, and the public on the FDA’s mission and responsibilities. The credibility of the Alliance is based upon the breadth of its membership and the robust support of the FDA by Congress, policymakers, and the public.  

For those in this room, consider forming the Alliance for a Stronger CPSC.  The agency’s funding is often compromised unless a crisis emerges. The Alliance today has an especially important voice as we see the slashing of budgets and dismissal of our federal workforce that protects safety and health in the name of cutting government waste.  

The Alliance for a Stronger FDA is speaking out with one voice about those issues right now, and the fact that it represents such a broad constituency speaks volumes and can reach every congressional district.  

Thank you all for what you do every day to protect consumers and make wonderful products. I’m very honored that you invited me to present the Keynote today, and I look forward to your questions. 

###

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.

House budget resolution bad for consumers and America

Budget blueprint would slash Medicaid and eliminate vital manufacturing and green energy policies

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

Washington, DC – Today, House Republicans released a budget resolution, which guides federal spending and revenue policies and initiates the reconciliation process.  The resolution calls for at least $1.5 trillion in spending reductions and $4.5 trillion in tax cuts.  The accompanying “budget blueprint” lays out a series of proposals that would eliminate core manufacturing and clean energy policies established in the Inflation Reduction Act and severely weaken Medicaid, which provides health insurance for nearly 72 million Americans.

“So much for America first,” said Sally Greenberg, CEO of the National Consumers League. “The House Republican’s budget resolution puts everyday Americans last and corporate interests first.  No matter where you live—in a red state or blue state—this budget will hurt consumers. The proposed draconian cuts to Medicaid could deprive millions of hardworking Americans of access to affordable, quality healthcare.  Eliminating vital manufacturing and clean energy policies will harm our nation’s competitiveness, workforce, environment, and health. All of this for the sake of tax breaks for ultra-wealthy corporations that merely pocket the taxes and ship jobs overseas anyway. This is bad for consumers and bad for America.”

###

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.

Consumer groups file comments supporting DOT delay compensation rules 

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

Washington, DC – Yesterday, the National Consumers League (NCL) and four other public interest organizations filed comments with the U.S. Department of Transportation (DOT) urging the Department to implement passenger protections in the event of significant flight delays and cancellations. Under federal law enacted last year, DOT must act on the issue by May 16.

NCL, the American Economic Liberties Project, Consumer Action, the Consumer Federation of America, and Travelers United called for:

  • Automatic cash compensation to consumers affected by flight disruptions that could have been prevented by the carrier
  • Food, drink, and lodging during disruptions
  • Maximum customer service wait times of 10 minutes
  • Rebooking on the next available flight
  • Prompt notice to disrupted travelers of their legal rights

The full comments can be found here.

Further reading:

### 

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. 

Trump import tariffs harm small businesses and consumers: increased costs and delays ahead

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

Washington, DC – The National Consumers League (NCL) is deeply concerned about the Trump administration’s recent announcement of new tariffs on imports from Canada, Mexico, and China. NCL is fearful that this decision could significantly impact American consumers, affecting a wide range of goods that are integral to daily life.

As of this week, an agreement was made between the two North American countries to delay the tariffs for 30 days. This temporary pause allows time to see if these actions can lead to a solution without the need for harsh tariffs. If the agreements are not met or progress is not made, the tariffs could go back into effect after the 30-day period.

While these tariffs are framed as efforts to address national security concerns, the reality is that they could place an undue burden on everyday Americans. Consumers are already facing inflationary pressures, and these additional costs may only exacerbate the financial challenges that families and businesses face. The proposed 25% additional tariff on all imports from Canada and Mexico, along with a 10% tariff on energy resources, will directly drive-up prices on essential goods. NCL is concerned that consumers could feel the impact when they purchase everything from groceries to vehicles, as the increased tariffs is expected to add to the cost of manufacturing and transportation. An estimate from the non-partisan Tax Foundation puts the cost of the proposed tariffs at $800 per household this year.

“We are deeply concerned that these tariffs could hurt everyday Americans,” NCL CEO Sally Greenberg said. “Products consumers rely on daily, from fruits and vegetables to meat and energy could see price increases as supply chains are disrupted. Higher prices on basic goods would make life harder for families across the country, all as a result of these ill-conceived trade policies.”        

###

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.

 

Fifteen organizations call on senate commerce committee to support TICKET Act  

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

Washington, DC – Today, the National Consumers League (NCL) joined a coalition of 15 organizations in support of the TICKET Act (S. 281). This bipartisan bill, reintroduced in the Senate by Senators Edward Markey (D-MA) and Eric Schmitt (R-MO), is scheduled for markup in the Senate Commerce Committee this Wednesday, February 5. NCL has championed this legislation since its introduction last Congress and continues to stand with numerous consumer and fan advocacy organizations and live event industry stakeholders in endorsing its key provisions.  

“Consumers deserve fair, transparent, and reliable ticketing practices, and the TICKET Act delivers just that,” said John Breyault, NCL Vice President of Public Policy, Telecommunications, and Fraud. “Hidden fees, speculative ticketing, and deceptive marketing practices have plagued the live event industry for far too long, leaving fans frustrated and out of pocket. The TICKET Act takes important steps toward fixing these issues, and NCL is proud to continue our support for this vital consumer protection legislation.”  

The TICKET Act requires all-in pricing, which would eliminate hidden fees and provide consumers with clear and transparent pricing upfront. It also bans speculative ticketing and deceptive marketing practices, ensures refunds for canceled or postponed events, and mandates a Federal Trade Commission (FTC) study on the enforcement of the BOTS Act.  

“The TICKET Act’s common-sense provisions will empower consumers and promote a more equitable and transparent live event ticketing marketplace,” said Breyault. “By supporting this bill, the Senate has the opportunity to protect millions of fans from deceptive practices and ensure that ticket buyers can confidently purchase tickets without fear of hidden costs or other unfair practices.” 

To view the organizations’ letter, click here. 

 ### 

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

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.

###

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

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.

###

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 urges swift passage of the TAKE IT DOWN Act

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

Washington, D.C. – Last week, U.S. Senators Cruz and Klobuchar reintroduced the TAKE IT DOWN Act, a bill that would make it illegal to post non-consensual intimate imagery (NCII) and require platforms to remove such content within 48 hours of notice. NCL strongly supports the TAKE IT DOWN Act and calls on the new Congress to prioritize swift passage of the measure. Last year, the legislation passed the Senate and was set to clear the House of Representatives, until Elon Musk intervened in end-of-year negotiations. 

“The TAKE IT DOWN Act has overwhelming bipartisan support. There’s no reason this can’t pass within the first 100 days.” said NCL Senior Public Policy Manager Eden Iscil. “Victims of NCII shouldn’t face pushback from digital platforms when they ask for the images of themselves to be removed. This bill would make that request a federal right.” 

The legislation also covers AI-generated NCII (i.e. deepfakes), a growing issue that can be just as damaging as in-person photography. 

###

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.

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

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.

###

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

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

 

###

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.