Prop. 65 - Labeling vs. Disclosure Requirements


Question: I already comply with Proposition 65 by labeling my product. Why am I also asked to provide a declaration of compliance? Do I have to provide a declaration, since my products are correctly labeled?

 Answer: Labeling your product and providing a declaration are two separate requirements. Your customer, who requested this declaration, also has an obligation to label their finished product. To do that, they need to identify instances where listed Proposition 65 substances occur in their product, including in its component parts and materials. 

 The information in your declaration will help your customer make a determination about any exposure risk to listed substances in their finished product. This allows them to meet their labeling or warning requirements under Proposition 65. Your declaration of compliance provides documentation that is a necessary part of the due diligence process. 

 Article valid as of September 20, 2019.

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