Thayer Elizabeth Ellis

Food & Consumer Product Regulatory Compliance

Thayer helps clients understand and adhere to the complex matrix of safety regulations governing the food and consumer product industries, including providing guidance on product safety standards, reporting obligations, product recalls and risk assessments.

She guides clients on compliance with regulations enforced by the FDA, USDA, FTC and CPSC, including the Federal Food, Drug, and Cosmetic Act, the Consumer Product Safety Act (CPSA), Consumer Product Safety Improvement Act (CPSIA), Federal Hazardous Substances Act (FHSA), Poison Prevention Packaging Act (PPPA), Reese’s Law, the Virginia Graeme Baker Pool and Spa Safety Act, and other regulations. Thayer has represented a diverse range of clients, including manufacturers, distributers and retailers, helping them safeguard their reputations and manage regulatory compliance, including developing internal safety protocols, ensuring timely and accurate reporting, and managing CPSC investigations, enforcement actions, and recall events.

Thayer’s aptitude for tracking and anticipating emerging federal and state regulatory challenges means she is one step ahead when it comes to counseling clients on compliance with state environmental laws, such as Extended Producer Responsibility (EPR) laws, state laws related to food ingredients and ultra-processed foods, state recycling and recyclability issues, postconsumer recycled content (PCR), and many other state regulations that directly impact food and consumer product packaging.

Thayer also works with food and consumer product industry clients on supply-chain contracts and transactional matters, including due diligence in connection with sales or acquisitions of companies. She provides regulatory support in food and beverage litigation.

Product Development, Labeling, Marketing & Advertising

Thayer collaborates with clients’ product development and marketing teams to develop and launch new food, beverage, cosmetic and consumer products, enabling clients to bring innovative products to market with confidence. She performs in-depth label and ingredient reviews, and analyzes substantiation for claims, ensuring compliance with all industry regulations, and anticipating potential regulatory and litigation risks related to labeling, advertising, marketing, and social media materials and campaigns.

She works with clients to understand company risk tolerance and provides strategic counseling with a constant eye toward mitigating enforcement and litigation risks. Thayer has experience working with chemists and toxicologists to establish compliance of product components under the Federal Food, Drug, and Cosmetic Act.

Food Safety

She advises on the management of foodborne illness outbreaks, accidental adulteration, misbranding, and food allergen issues, including recalls and market withdrawals, inspections, warning letters, and enforcement actions.

Prior Experience

Thayer has several years of international legal experience. While based in São Paulo, Brazil, she aided multinational companies in bringing new food and drug products into the Brazilian market, including the preparation of clinical research programs and contracts.

Following law school, Thayer held a federal clerkship with the U.S. Department of Labor Office of Administrative Law Judges and served as an attorney advisor with the U.S. Department of Homeland Security Office of the Principal Legal Advisor.

Personal Interests

Outside the office, Thayer enjoys biking and fitness, international travel, and doing anything to make her kids laugh.