Skip to Main Content


Holland & Hart News Update

Selling Direct: Network Marketing Compliance and Practice

By Brent Johnson, Co-Author

Welcome to the latest edition of our “Selling Direct” client alert. In August we highlighted the legal issues surrounding “automatic renewal” distributor agreements, disclosures required for “unsafe” cosmetic ingredients, and our interactive Prop 65 quiz – a copy of this prior edition can be accessed here.

In this edition, we discuss the questions we hear most: What can I do with CBD oil? And how does the 2018 Farm Bill impact CBD products I’m hoping to develop and bring to market? (Read More)

We also discuss Supply Chain Transparency – highlighting a number of cases coming out of the Ninth Circuit where food manufacturers were found not liable for failing to disclose modern slavery in their supply chains (Read More) – and how large food retailers and producers are coming together to use the blockchain to develop robust supply chain transparency (Read More).

We also follow up our Prop 65 Q&A with an article highlighting that it is not all rosy for Prop 65 bounty hunters – a federal court ruled that Monsanto would not be required to post Prop 65 warnings based on uncertain science – a California Court of Appeals ruled that breakfast cereal manufacturers are not required to provide Prop 65 warnings based on preemption – and OEHHA overruled itself – taking the wind out of the blockbuster coffee case by ruling coffee roasters are exempt from Prop 65 (Read More).

This publication is designed to provide general information on pertinent legal topics. The statements made are provided for educational purposes only. They do not constitute legal or financial advice nor do they necessarily reflect the views of Holland & Hart LLP or any of its attorneys other than the author(s). This publication is not intended to create an attorney-client relationship between you and Holland & Hart LLP. Substantive changes in the law subsequent to the date of this publication might affect the analysis or commentary. Similarly, the analysis may differ depending on the jurisdiction or circumstances. If you have specific questions as to the application of the law to your activities, you should seek the advice of your legal counsel.


Unless you are a current client of Holland & Hart LLP, please do not send any confidential information by email. If you are not a current client and send an email to an individual at Holland & Hart LLP, you acknowledge that we have no obligation to maintain the confidentiality of any information you submit to us, unless we have already agreed to represent you or we later agree to do so. Thus, we may represent a party adverse to you, even if the information you submit to us could be used against you in a matter, and even if you submitted it in a good faith effort to retain us.