Summary#
S-4823, the Connected Consumer Product End of Life Disclosure Act, is an introduced bill that would supplement New Jersey’s Consumer Fraud Act. Its goal is to make buyers and product owners aware of how long a connected product is guaranteed support and what may happen when that support ends. It is not law; it has been referred to the Senate Commerce Committee.
- Manufacturers would have to disclose a product’s minimum guaranteed support time frame to prospective buyers at the point of sale where they can make the disclosure.
- The support period must be reasonable in light of factors such as price, intended use and consumer expectations. It cannot be shortened after disclosure, but may be extended.
- Manufacturers would have to post the support period and a detailed account of features and functions lost at end of life on the product’s web page.
- Manufacturers would have to notify product owners six months before support ends and again on the end-of-life date. Notices must describe ways to keep using the product securely, features that will be lost and vulnerabilities likely to result.
- The bill would treat non-compliance as an unlawful practice under the Consumer Fraud Act. It would also let a person aggrieved by a violation seek court relief and specified costs and damages.
What it means for you#
- People buying connected products: You would be entitled to see the manufacturer’s support commitment at the point of sale when the manufacturer can make that disclosure. The bill does not require a retailer to make the disclosure.
- People who own covered products: You would have to receive end-of-life notices six months before support ends and on the end-of-life date, through one or more of the methods listed in the bill. The notice must include steps such as disconnecting the product from the Internet.
- Manufacturers: The bill defines this group to include people or businesses manufacturing, assembling or distributing connected products in New Jersey. They would have to meet the disclosure and notice duties, including for products sold or offered for sale on or after July 1, 2025.
- Product owners who are harmed by a violation: The bill allows an aggrieved person to seek an injunction or declaratory relief and recover listed costs and damages, reasonable legal fees and other relief the court finds appropriate.
- The bill does not require manufacturers to keep supporting products indefinitely, or guarantee that a product will remain secure after support ends. It requires a stated support commitment and end-of-life disclosures.
Money#
No cost estimate is included in the supplied material.
- Manufacturers would face costs to prepare and provide disclosures; no estimate is given.
- The bill requires the Division of Consumer Affairs director to adopt rules. It gives no staffing or implementation cost estimate.
- The bill’s accompanying statement says violations may carry Consumer Fraud Act penalties of up to $10,000 for a first offense and $20,000 for later offenses. The bill text itself refers to penalties provided by law but does not set those amounts.
- A person aggrieved by a violation could seek the costs and damages listed in the bill, including repair or replacement costs, consequential damages and legal fees.
What is unclear#
- The bill does not set a fixed number of years for support. It says the period must be “reasonable,” but does not define that term.
- The requirement that support be “no less than one year before the product’s end of sale” is unclear about how to measure the required period.
- The bill does not explain how manufacturers must identify or reach product owners who lack contact information, or how the notice options apply in each case.
- The bill does not specify how its retroactive application would work for products sold or offered before the law takes effect.
- The supplied material does not include the current Consumer Fraud Act, so it is not possible to verify how the bill’s remedies and penalties would interact with existing law.
Case for#
- A buyer could compare support commitments before purchase rather than discover later that a connected product has lost updates or features.
- A clear end-of-life notice could give owners time to decide whether to change how they use a product, including disconnecting it from the Internet.
- Requiring manufacturers to state and honor a support period could make it harder to reduce a commitment after buyers have relied on it.
Case against#
- The bill does not set a clear minimum support duration in years; the “reasonable” standard could leave manufacturers and buyers uncertain about what is required.
- The bill requires broad disclosures and allows significant claims for damages, but does not spell out detailed procedures for proving a violation or calculating damages.
- Applying the rules to products sold or offered since July 1, 2025, could create uncertainty about what manufacturers must do for products already on the market when the law takes effect.