California Proposition 65 Labeling requirements

Question Posed:

What are the labeling requirements under the California Proposition 65 regulation?

Answer Provided:

Page 6 of Assent’s white paper (available here: https://info.assentcompliance.com/proposition-65-170215) includes the new label requirements. Listed below are the other warnings requirements when a label is not being used.

  • 25603 Consumer Products Warnings

(a) Warnings for consumer products exposures that include the methods of transmission and the warning messages as specified by this section shall be deemed to be clear and reasonable.

(b) To the extent practicable, warning materials such as signs, notices, menu stickers, or labels shall be provided by the manufacturer, producer, or packager of the consumer product, rather than by the retail seller.

(c) A person in the course of doing business, who manufactures, produces, assembles, processes, handles, distributes, stores, sells, or otherwise transfers a consumer product which he or she knows to contain a chemical known to the state to cause cancer or reproductive toxicity in an amount that requires a warning shall provide a warning to any person to whom the product is sold or transferred unless the product is packaged or labeled with a clear and reasonable warning.

The label should include at least one of the substances that requires the warning.  A full list is not required, but the more info the better to avoid issues if the product contains multiple substances over the safe harbor level where the user could be exposed.

Reference: https://oehha.ca.gov/media/downloads/crnr/art6regtextclean090116.pdf

**Article contents valid as of 2017-06-22

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