California Prop 65’s Short-form Warnings Will No Longer Be Short – Summary of Amendments to Short-form Warnings under California Proposition 65 – Effective January 1, 2025 with Three-Year Grace Period
After what has amounted to a multi-year rulemaking process, the
California Office of Environmental Health Hazard Assessment (OEHHA)
finalized amendments to the short-form warnings under Proposition
65 on December 6, 2024. The amendments (outlined in full here)
require that short-form warnings include at least one chemical name,
along with other options for safe harbor warning. There is also a
specialized short-form warning for food. Specific long-form warnings
were also added for Passenger, or Off-Highway Motor Vehicle Parts
and Recreational Marine Vessel Parts. While the amendments become
effective on January 1, 2025, OEHHA has provided businesses that
currently rely on the existing short-form warnings three years (until
January 1, 2028) to transition to the new short-form content.
The original short-form safe harbor warnings promulgated as part of
the 2018 overhaul of Proposition 65’s “clear and reasonable” warning
requirements were fairly straightforward. If a warning label could fit on
a product or its immediate packaging, a warning involving, for example,
a chemical known to cause cancer, could simply state “Warning:
Cancer – www.p65warnings.ca.gov” along with the warning symbol.
Read the full insight to learn more about these amendments.