Cynthia Lieberman counsels domestic and international clients engaged in the manufacturing and marketing of food and drug packaging materials, food and feed additives, cosmetics, and components of medical devices. She assists clients in determining the compliance status of their products and, if necessary, to obtain premarket authorizations from the relevant regulatory authorities. Cynthia assists clients in interpreting emerging regulatory requirements, for example, those arising from the U.S. Food and Drug Administration's (FDA) temporary guidance issued to companies in the wake of the COVID-19 pandemic. As counsel to industry coalitions and trade associations, Cynthia provides strategic advice and regulatory support to further the policy interests of member companies throughout the food packaging supply chain.
Cynthia is frequently invited to speak at international food contact conferences and is an associate editor and contributing author for packaginglaw.com, which provides news and analysis on worldwide packaging regulations.
Representative Matters
- Evaluated food contact materials and articles and provided legal opinions on the regulatory status of these products in numerous jurisdictions around the globe, including the U.S., European Union, Latin America, China, Japan, and India, among others
- Prepared and submitted Food Contact Notifications (FCNs) to obtain premarket clearances from FDA for food contact substances
- Filed dossiers to attain premarket authorizations for food contact materials under the EU Plastics Regulation, China’s GB 9685 Standard, the MERCOSUR Resolutions in South America, and other comparable international authorities
- Guided the application process of the Generally Recognized as Safe (GRAS) principle and advised clients on the feasibility of establishing a self-determined GRAS position
- Counseled clients on good manufacturing practice considerations, including traceability and recordkeeping requirements
- Assisted with product recalls and potential contamination scenarios
- Interpreted and developed supplier and customer assurance documentation
- Requested Letters of No Objection (LNOs) from FDA regarding plastics recycling technologies and the use of post-consumer recycled plastics in food contact applications, and provided legal opinions on same
- Advised on product labeling obligations under California’s Proposition 65
Memberships
- American Health Lawyers Association