Breaking Down California’s New Proposition 65 Labeling Guidelines

The Office of Environmental Health Hazard Assessment published regulatory changes to the short-form warning label requirements in 2025. The changes will affect the short-form label requirements, including limitations on when they can be used, updates to the required language, and strict formatting guidelines.

Because of the stricter requirements, companies must investigate their supply chains to identify whether their products or components contain chemicals listed under Proposition 65.

Previously, short-form warning labels allowed a simplified format with a generic warning statement, “WARNING: Cancer, Developmental Toxicity, Male Reproductive Toxicity, & Female Reproductive Toxicity – www.P65Warnings.ca.gov.” The new short-form warning must include at least one chemical name associated with the risk being disclosed, “WARNING: This product can expose you to Lead, which is known to the State of California to cause Cancer, Developmental Toxicity, Male Reproductive Toxicity, & Female Reproductive Toxicity. For more information, visit www.P65Warnings.ca.gov.”

The new regulations became effective on January 1, 2025. There will be a three-year grace period, which ends on December 31, 2027. Products manufactured before January 1, 2025, may continue using the old warning labels if they meet the previous compliance standards. Businesses must demonstrate that the products were manufactured before January 1, 2025, and the warnings applied followed the prior regulations.

Starting January 1, 2028, full compliance with the new regulations will be mandatory, regardless of the manufacturing date. All products offered in California must display the updated short-form warnings and meet the revised content, format, and visibility standards.

Example below:

WARNING: Risk of developmental toxicity from exposure to Cycloheximide. See www.P65Warnings.ca.gov

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