California Prop 65 warnings for exporters: 2025 short-form label rules

How Proposition 65 works

California publishes a list of chemicals known to cause cancer, birth defects or other reproductive harm. It has grown to more than 800 chemicals since 1987 and is updated at least once a year. Businesses must give a clear and reasonable warning before knowingly and intentionally exposing anyone to a listed chemical, and have 12 months to comply after a chemical is listed. Businesses with fewer than 10 employees and government agencies are exempt. OEHHA has set more than 300 safe harbor levels, No Significant Risk Levels (NSRLs) for carcinogens and Maximum Allowable Dose Levels (MADLs) for reproductive toxicants, below which a warning is not needed.

The short-form warning since 2025

• Short-form warnings must now identify at least one chemical for each applicable endpoint (cancer, reproductive harm).
• Example for a carcinogen: "Cancer risk from exposure to [name of chemical]. See www.P65Warnings.ca.gov."
• The signal word can be "WARNING", "CA WARNING" or "CALIFORNIA WARNING".
• The new rules took effect on 1 January 2025.
• Products manufactured and labeled before 1 January 2028 can still be sold without relabeling; products made from that date must follow the new rules.

What exporters are asked for

The law is enforced by the California Attorney General, district attorneys, certain city attorneys and private individuals acting in the public interest, and penalties can reach $2,500 per violation per day. US importers, distributors and retailers therefore often ask foreign suppliers to confirm whether a product contains listed chemicals above the safe harbor levels, to provide test reports, and to apply the warning label on the product or packaging before shipment.