California Updates Proposition 65 Short-Form Warning Regulations

On December 6, 2024, California’s Office of Environmental Health Hazard Assessment (OEHHA) unveiled revisions to California Proposition 65, amending Sections 25601, 25602, 25603, and 25607.2 of Title 27 of the California Code of Regulations and adding new Sections 25607.50 through 25607.53.¹ This update was formally notified to the TBT Committee of the WTO on December 10, 2024.²

Key Revisions

1. Expanded Signal Words: Both long- and short-form warnings may now use additional signal words, such as "CA WARNING" or "CALIFORNIA WARNING," in addition to the current signal word "WARNING."

2. Chemical Identification Requirement: Short-form warnings must now specify at least one chemical name.

3. Font Restrictions Updated: The previous rule requiring the short-form warning font to be no smaller than the largest type size used for other consumer information has been lifted. However, a minimum font size of 6-point remains in effect.

4. Application to Food Products: Short-form warnings are now explicitly permitted on food product labels.

5. New Safe Harbor Warnings: Tailored warnings are introduced for passenger and off-highway motor vehicle parts, as well as recreational marine vessel parts.

6. Online Retail Transition Period: A 60-day transition window is established during the three-year implementation phase, allowing internet retailers to update online short-form warnings after receiving notice from manufacturers.

Examples of the Revised Short-Form Warning for Consumer Products

Implementation Timeline

The amendments took effect on January 1, 2025. Businesses have three-year transition period (until January 1, 2028) to fully adopt the revised short-form warning standards. Products produced after this date must adhere to the new labeling requirements. However, products labeled with existing short-form warnings before the transition period expires may continue to be sold indefinitely without relabeling, minimizing disruption to current inventory.

#Webinar

U.S. State Legislations for Cosmetics: An In-Depth Look at CaliforniaCalifornia has long been a pioneer in regulatory matters, setting stringent standards across various industries, including cosmetics. The state’s approach to cosmetics regulation is known for its comprehensive and often more stringent requirements compared to federal standards. This includes a focus on product safety, ingredient transparency, and environmental impact. California's regulations play a significant role in shaping the wider U.S. market, and the state has also led the charge on sustainability and health-related concerns, with laws addressing toxicity, labeling, and ingredient restrictions.In this webinar, Lily Li, a Senior Regulatory Specialist from REACH24H will provide a comprehensive overview of California’s cosmetics regulatory framework, covering key legislative actions like the California Safe Consumer Program and the California Proposition 65 law, along with recent efforts to restrict specific harmful chemicals. We will also explore how these regulations affect companies both in California and across the U.S. By the end of this session, participants will gain a clear understanding of the regulatory landscape for cosmetics in California and be better equipped to navigate these requirements in their operations.Notes:The webinar livestreaming is freely available to all users. You are welcome to register for and participate in the webinar.Kindly be aware that the access to the slides, recording, and Q&A collection is limited to ChemLinked premium members only [Upgrade now].