New Amendments Proposed to California Prop 65 Warnings

SGS, the world’s leading testing, inspection and certification company, is reminding operators in California of a further proposed revision to the ‘clear and reasonable’ warning under California Proposition 65 (Prop 65).

The California Office of Environment Health Hazard Assessment (OEHHA) has announced a second 15-day modification over additional updates to its proposed amendments to the ‘clear and reasonable’ warning.

The latest proposal:

  • Allows the use of short-form warnings on product labels of any size, regardless of package size and shape, by removing the limitations for the use of these product labels (Section 25602(a)(4))
  • Removes the provision where the font type size must be the same as the largest type size providing consumer information, but retains the requirement of a minimum of 6-point type size when using short-form warnings (Section 25602(a)(4)) – the entire warning must be clearly visible, easily legible, understandable and comply with Section 25601(c)
  • Modifies the language ‘exposes you to’ to ‘can expose you to’ (Subsections 25603(b) and 25607.2(b)
  • Changes the regulation’s operative date from ‘one year’ to ‘two years’ after the effective date of the amendments to allow businesses to implement changes to the short form

The latest 15-day modification on proposed amendments to Article 6 in Prop 65 was announced on April 5, 2022. It follows a Notice of Proposed Rulemaking (NPR) issued in January 2021 that led to an extended period of public comment, until March 2021. The OEHHA then held its first 15-day modification in December 2021.

Once accepted, the changes will become operative two years after the effective date of the amendments.

Stakeholders wishing to see examples of the new ‘clear and reasonable’ warnings should review SGS’s original SafeGuardS 049/22.

SGS Prop 65 Services

With a global network of laboratories, SGS can offer comprehensive testing, product assessment and consultancy services related to California Proposition 65. SGS can assist your risk management strategy in consumer goods, such as DIYs, electrical and electronics, hardgoods products, juvenile products, and textile & toy products. In the end, it’s only trusted because it’s tested. Learn more about SGS’s Prop 65 Services.

SGS SafeGuardS keep you up to date with the latest news and developments in the consumer goods industry. Read the full California Proposition 65: OEHHA Consults Over Modification of Proposed Revisions to Consumer Product Exposure Warnings SafeGuardS. [

Subscribe here to receive SGS SafeGuardS direct to your inbox.

For further information contact:

Dr. Hingwo Tsang

Global Information and Innovation Manager

Tel: (+852) 2774 7420



LinkedIn: sgs-consumer-goods-&-retail

About SGS

We are SGS – the world’s leading testing, inspection and certification company. We are recognized as the global benchmark for quality and integrity. Our 96,000 employees operate a network of 2,600 offices and laboratories, working together to enable a better, safer and more interconnected world.

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