As an attorney for the Cosmetics, Toiletry and Fragrance Association, Roberts lobbied against proposed labeling regulations for sunscreen products by threatening litigation. After Newsday broke the story that these contacts were omitted from his previous disclosures to the Senate, Roberts argued that he had not included these contacts because he had considered the discussion of litigation as a legal task rather than a lobbying task.

Newsday notes that Roberts worked for CTFA longer than mentioned in either the previous disclosures or the follow-up letter Roberts submitted in response to the Newsday investigation:

The group's executive, Edward Kavanaugh, said he had hired Roberts for two tasks, to draft a lawsuit based on First Amendment and commercial free speech issues, and to work on the labeling of cosmetics like lipstick treated as over-the-counter drugs. But he did not return calls seeking clarification on when he hired Roberts.

An FDA record shows that on Jan. 4, 2000, Roberts and the cosmetic group's general counsel met with FDA officials to discuss a final rule for labeling over-the-counter drug products. The FDA calendar shows that in October 2001 Roberts and cosmetic association officials, including Kavanaugh, met with FDA lawyers about sunscreen labeling.

Hogan & Hartson did not register as a lobbyist for the cosmetics group until March 20, 2001. It filed that registration and a report on the first six months of 2001 in August 2001, and noted Roberts had met with [officials at the White House Office of Management and Budget (OMB)].

Roberts' meeting with OMB’s Office of Information and Regulatory Affairs back in 2001 was recorded in a handwritten meeting log. OIRA now posts these meetings online. OMB Watch has an archive of meeting logs that OIRA did not post electronically.