Summary

Requires manufacturers of internet-connected consumer products that include a camera or microphone to disclose clearly and conspicuously to buyers, before purchase, whether the device contains a camera or a microphone. The Federal Trade Commission enforces the rule as an unfair or deceptive practice, must issue guidance within 180 days to help manufacturers comply, and the rule applies to devices manufactured more than 180 days after the FTC issues that guidance (devices already in commerce are excluded).

Key Points

• Manufacturers must disclose before sale if an internet-connected consumer product contains a camera or a microphone.
• Disclosures must be clear and conspicuous and state whether a camera and/or microphone is present.
• The FTC enforces violations as unfair or deceptive acts under the FTC Act.
• The FTC must issue compliance guidance within 180 days and may provide tailored guidance on request.
• The law covers consumer products that connect to the internet and include camera or microphone components, with several specific device exemptions.
• The requirement applies to devices manufactured more than 180 days after the FTC issues its guidance; earlier devices are exempt.
• Guidance from the FTC cannot create private legal rights or replace statutory elements the FTC must allege in enforcement actions.
• The law emphasizes transparency at point-of-sale rather than imposing technical or data-collection restrictions.

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