My understanding is that one cannot enact a law that requires specific actions *before* the law was passed, so if that's true, it's unlikely that Justice would try to enforce the regulations on content that was "published" before the law took effect.
The catch is what "published" means... and there was a lot of discussion about that on one of the legal panels a year or so ago when the new 2257 regs were being discussed.
However, if you're being conservative, it's wise to assume that all content, regardless of publication date, should be compliant until the justice department indicates otherwise.






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