Outside FDA, Inside the Crosshairs: Cybersecurity Risks for General Wellness and Fitness Products

In Part One of this series, we discussed how wellness products sit at the intersection of Food and Drug Administration (FDA), Health Insurance Portability and Accountability Act (HIPAA), Federal Trade Commission (FTC), and state privacy/breach laws. In Part Two, we analyzed FDA’s 2026 General Wellness guidance and what it means for device-level cybersecurity expectations. In this final installment, we focus on the cybersecurity risks and legal obligations that apply even when a product qualifies... By: Troutman Pepper Locke