News & Analysis as of

Proposition 65 Warning Labels Chemicals

Keller and Heckman LLP

May 2025 Bounty Hunter Plaintiff Claims

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California’s Proposition 65 (“Prop. 65”), the Safe Drinking Water and Toxic Enforcement Act of 1986, requires, among other things, sellers of products to provide a “clear and reasonable warning” if use of the product results...more

Farella Braun + Martel LLP

The approaching warning deadline for vinyl acetate

On January 3, 2025, vinyl acetate was added to the Prop 65 list as a carcinogen. Vinyl acetate is a synthetic chemical, and a colorless liquid with a sweet, fruity smell. In its Evidence on the Carcinogenicity of Vinyl...more

Sheppard Mullin Richter & Hampton LLP

Navigating the Legal Soup: A New “Short-Form” Recipe for Prop 65 Warnings on Food and Beverages

Until this year, food companies—often the target of Proposition 65 enforcement actions—have been limited to specific “full-length” language for Prop 65 warnings, without explicit guidance regarding whether short-form warnings...more

Foley & Lardner LLP

Prop 65: Changes to Short-Form Warnings Will Cause Long-Term Impacts

Foley & Lardner LLP on

The California Office of Environmental Health Hazard Assessment (OEHHA) recently amended its regulations concerning requirements for consumer product warnings to qualify for “safe harbor” protection from enforcement actions...more

Keller and Heckman LLP

March 2025 Bounty Hunter Plaintiff Claims

Keller and Heckman LLP on

California’s Proposition 65 (“Prop. 65”), the Safe Drinking Water and Toxic Enforcement Act of 1986, requires, among other things, sellers of products to provide a “clear and reasonable warning” if use of the product results...more

Greenberg Glusker LLP

Paper Problems: BPS in Thermal Receipts Triggers Prop. 65 NOVs

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California shoppers might be getting more than just a receipt at checkout — they may also be exposed to a toxic chemical, according to Proposition 65 (“Prop. 65”) enforcer Center for Environmental Health (CEH) represented by...more

Hahn Loeser & Parks LLP

California’s Proposition 65: Recent 60-Day Notices Target California Restaurants

Hahn Loeser & Parks LLP on

A recent uptick in Proposition 65 notices of violation have targeted California restaurants. These notices are issued from a particular private enforcer (or bounty hunter), but such trends often prompt others to follow suit....more

Farella Braun + Martel LLP

The looming BPS warning deadline, Chris Rendall-Jackson

On December 29, 2023, OEHHA listed bisphenol S (BPS) under Prop 65 as a chemical known to the State of California to cause female reproductive toxicity. In its Evidence on the Female Reproductive Toxicity of Bisphenol S,...more

Kelley Drye & Warren LLP

California Revises Proposed Amendments to Prop 65 “Short-Form” and Internet Warnings; Extends Compliance Period

Roughly eight months have passed since California’s Office of Environmental Health Hazard Assessment (OEHHA) last proposed to amend its Prop 65 regulations on ​“short-form” and internet warnings provisions. Now, in response...more

Sheppard Mullin Richter & Hampton LLP

Proposition 65: 2023 in Review

2023 was a busy year for Prop 65 with the highest number of Notices of Violation since its inception. The California law requires consumers receive warnings regarding the presence of chemicals that cause cancer or...more

Sheppard Mullin Richter & Hampton LLP

The Intersection of Prop 65 and Free Speech: A Recent Win for Businesses

Under California’s Proposition 65 (“Prop 65”), businesses are required to give “clear and reasonable warnings” to consumers regarding potential chemical exposure if their product contains a chemical “known to the state to...more

Kelley Drye & Warren LLP

The California Prop 65 Acrylamide Saga Continues

Before the close of 2022, California’s Office of Environmental Health Hazard Assessment (“OEHHA”) officially finalized two big acrylamide regulations under the state’s Proposition 65 program. First, after nearly three years...more

Sheppard Mullin Richter & Hampton LLP

WARNING: Get Your Prop 65 House in Order for the New Year

Companies should regularly assess their Prop 65 compliance. Products, packaging, business relationships, and the rules for compliance are constantly changing. Start 2023 off right with a review of your compliance practices to...more

Kelley Drye & Warren LLP

California Still Seeking Proper Balance for Prop 65 Short Form Warnings

The California Office of Environmental Health Hazard Assessment (OEHHA), which manages the state’s Proposition 65 program, is reviewing comments on its latest attempt to limit use of the popular “short form” warning option. ...more

ArentFox Schiff

California Dials Back Proposed Amendments Restricting Use of Proposition 65 Short-Form Warnings 

ArentFox Schiff on

On April 5, 2022, in response to comments and opposition from companies and trade organizations over the last year, the agency governing Proposition 65, the California Office of Environmental Health Hazard Assessment (OEHHA),...more

Kilpatrick

5 Key Takeaways: California Proposition 65 & Other Hazards in the Stream of Commerce

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Kilpatrick Townsend’s Alex Bullock and Laura Miller recently presented to clients at the firm’s 2022 Small Legal Department Client Summit. They discussed “California Proposition 65 & Other Hazards in the Stream of Commerce.” ...more

Kelley Drye & Warren LLP

The Prop 65 Pandemic: No Covid Slow-Down for Enforcement

While the Covid-19 pandemic caused all sorts of disruptions to society and the economy, at least one area of business has thrived over the last two years: private plaintiff enforcement of California Proposition 65. In...more

Kelley Drye & Warren LLP

Court Injunction Hints at Prop 65 Relief for Acrylamide in Foods

In the latest of a string of potentially ground-altering developments under California’s Proposition 65, a federal judge has temporarily enjoined plaintiffs from initiating new cases alleging failure to warn for foods and...more

Perkins Coie

Proposition 65’s Imminent Enforcement Date for THC: Is Your Cannabis Business Ready?

Perkins Coie on

Proposition 65 warning requirements announced last year are set to be enforced starting January 3, 2021; if your business is selling cannabis products in California, now is the time to ensure that your labeling complies with...more

Bergeson & Campbell, P.C.

California to Consider Prop 65 Listing for Glyphosate, Neonicotinoids, and Other Substances

On October 6, 2020, the California Developmental and Reproductive Toxicant Identification Committee (DARTIC) announced it will be meeting on December 11, 2020, to discuss the possible developmental and reproductive toxicity...more

Kelley Drye & Warren LLP

The Prop 65 Annual Conference: Notes from the Front 2020

(Virtually) Live from San Francisco, Kelley Green Law Blog is reporting today from the Prop 65 Clearinghouse 2020 Conference …. the largest annual assemblage dedicated to the legal niche that is California’s “Proposition 65.”...more

ArentFox Schiff

Alert Newsletter: Challenge To Coffee-Causes-Cancer Label To Continue, Possibly Resolve Dozens of Lawsuits Against Businesses

ArentFox Schiff on

Challenge To Coffee-Causes-Cancer Label To Continue, Possibly Resolve Dozens of Lawsuits Against Businesses - Legal Newsline - A California federal court has refused to throw out a lawsuit that challenges the state’s...more

Husch Blackwell LLP

California’s OEHHA Proposes Regulation Requiring Warning For Acrylamide In Food

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On August 4, 2020, the Office of Environmental Health Hazard Assessment (OEHHA) proposed to amend the Proposition 65 regulations. Proposition 65, also known as the Safe Drinking Water and Toxic Enforcement Act of 1986,...more

Kelley Drye & Warren LLP

Managing the Feeding Frenzy: OEHHA Proposes Limits on California Prop 65 Requirements for Acrylamide in Food

California’s Office of Environmental Health Hazard Assessment (OEHHA) has proposed regulations to limit the rash of Proposition 65 actions alleging failure to provide a warning for exposure to acrylamide in food items as a...more

Perkins Coie

An Introduction to California's Proposition 65: What is Proposition 65?

Perkins Coie on

Welcome to the first in a multipart series of posts regarding California’s Proposition 65 (Prop. 65). This piece introduces readers to the law and its requirements. Future posts will dive deeper into analysis and trends...more

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