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CT AG Warns Sephora Over Marketing Harmful Skincare to Children

SephoraNovember 25, 2024Connecticut Attorney General

Summary

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.

Contract Impact

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.

Contract Search Terms

marketing to minors clauseage verification requirementproduct warning disclosuresocial media influencer contract termschildren's privacy protectionharmful ingredients labelingsearch result filtering for minorsparental consent mechanismadvertising to children restrictionsproduct placement guidelines

Violation Types

Entity Details

Entity

Sephora

Industry

Retail

Official Sources

Related Enforcement Actions

CT

Sephora

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.

CT

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CT

TaxAct

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