Do I need to name more than one substance on a revised Proposition 65 short-form warning label?

No, the new short-form warning label only requires you to name one specific chemical and its associated health risk. If your product contains multiple listed substances, you should work with your compliance and legal teams to determine which one to include on the label. It’s important that the named chemical and its health risk match what’s in the OEHHA list.

Are internet retailers (e-commerce) in scope of the new warning label requirements?

Yes, internet retailers selling into the state of California are in scope of this ruling. Like brick and mortar manufacturers, they have a three-year grace period to start using the revised short-form warning format.

Will U.S. federal regulations affect this new ruling?

Proposition 65 is a strong example of how U.S. states are leading the charge in setting their own product compliance standards. Because the California Safe Drinking Water and Toxic Enforcement Act is enacted and enforced at the California state level, factors at the federal level (such as EPA staffing or budgets) do not affect or delay the revised warning label ruling.

Can I purchase generic revised short-form warning labels?

Because the new rules are designed to increase transparency for consumers, companies can no longer use a single “generic” label. Supply chain due diligence is necessary. To comply, you will first need to engage suppliers and identify at least one substance in your product(s) to understand what information to provide on a label.

Is there a product testing requirement for Proposition 65 warning labels?

No. Collecting information from your suppliers about the chemicals in their products is considered adequate due diligence to create a compliant short-form label.

Which listed substances are at higher risk for enforcement under Proposition 65?

While all listed substances can create enforcement risk if not properly disclosed according to labeling requirements, there are a number of substances considered at a higher risk:Phthalate(s)LeadCadmiumHexavalent chromiumNickelAcrylamidePer- and polyfluoroalkyl substances (PFAS), including PFOA and PFOSBisphenol-A (BPA)BenzeneCarbon monoxideTitanium dioxideMercuryMethylene chloride

Do I need to name more than one substance on a revised Proposition 65 short-form warning label?

No, the new short-form warning label only requires you to name one specific chemical and its associated health risk. If your product contains multiple listed substances, you should work with your compliance and legal teams to determine which one to include on the label. It’s important that the named chemical and its health risk match what’s in the OEHHA list.

Are internet retailers (e-commerce) in scope of the new warning label requirements?

Yes, internet retailers selling into the state of California are in scope of this ruling. Like brick and mortar manufacturers, they have a three-year grace period to start using the revised short-form warning format.

Will U.S. federal regulations affect this new ruling?

Proposition 65 is a strong example of how U.S. states are leading the charge in setting their own product compliance standards. Because the California Safe Drinking Water and Toxic Enforcement Act is enacted and enforced at the California state level, factors at the federal level (such as EPA staffing or budgets) do not affect or delay the revised warning label ruling.

Can I purchase generic revised short-form warning labels?

Because the new rules are designed to increase transparency for consumers, companies can no longer use a single “generic” label. Supply chain due diligence is necessary. To comply, you will first need to engage suppliers and identify at least one substance in your product(s) to understand what information to provide on a label.

Is there a product testing requirement for Proposition 65 warning labels?

No. Collecting information from your suppliers about the chemicals in their products is considered adequate due diligence to create a compliant short-form label.

Which listed substances are at higher risk for enforcement under Proposition 65?

While all listed substances can create enforcement risk if not properly disclosed according to labeling requirements, there are a number of substances considered at a higher risk:Phthalate(s)LeadCadmiumHexavalent chromiumNickelAcrylamidePer- and polyfluoroalkyl substances (PFAS), including PFOA and PFOSBisphenol-A (BPA)BenzeneCarbon monoxideTitanium dioxideMercuryMethylene chloride

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Product Compliance

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REACH
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TSCA
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Prop 65
Uncover deep supply chain data to meet labeling requirements.
PFAS
Identify PFAS in your supply chain and set yourself up for success.
EPR Packaging
Collect packaging data, estimate fees, and generate EPR compliance-ready reports.
Full Materials Disclosures
Learn how we use FMDs to deep-map the entire complex manufacturing genome.
AD-DSL
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EU Medical Device Regulation
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DFARS Specialty Metals
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EU Batteries Regulation
Jumpstart compliance and protect your EU market access.
CBAM
Easily see and manage the embedded emissions data of your goods.
EUDR
Our AI-enhanced solution helps manufacturers meet deforestation-free requirements.
CSRD
Confidently identify the entities and topics in your value chain that are most critical to compliance.
Conflict Minerals
Deep transparency into mineral sourcing.
Extended Minerals (Cobalt + Mica)
Our complete responsible minerals solution, including cobalt and mica reporting.
Supply Chain Due Diligence Act
Meet your German Supply Chain Due Diligence Act (SCDDA) requirements with confidence.
ABAC
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Forced Labor
Uncover hidden forced labor risks in your supply chain.
Supplier Code of Conduct
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Supplier Diversity
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Country of Origin
Country of origin tracking supply chain solutions.
Metal Sourcing
Verify the origin of your metals to avoid costly fines and delays.
Canada-EU Trade Agreement (CETA)
Unlock supply chain transparency to mitigate trade risks.
HS/HTS Codes
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International Trade Agreements
Protect global market access & leverage trade agreements.
USMCA
Uncover hidden risks and opportunities associated with the USMCA.
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Solutions for export classification code tracking.

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Solutions for the electronics industry, across compliance and ESG.
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Supply chain sustainability for automotive.

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Unify every customer compliance and sustainability request in one AI-powered platform - helping you respond faster, reduce manual work, and strengthen customer trust.
Enhanced Supplier Screening
Evaluate and report on hidden risks in your supply chain.
Data Information & Security
Learn about our data security protocols, to keep your information safe.
Enterprise Integrations
View our integrations with SAP, PTC Windchill, and other standard APIs.
Reporting & Data
Reporting and data capabilities you need to meet your requirements.
Why Assent
Assent is on a mission to help manufacturers build deeply and durably good products.

Services

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Supplier Engagement
Education, data collection, and technical support for suppliers.
Program Management
Managed services with dedicated support from world-class experts.
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View our integrations with SAP, PTC Windchill, and other standard APIs.

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Interactive Tools, Webinars, Whitepapers, Guides and eBooks.Visit the Content Hub
Supply Chain Risk Assessment Tool
Supply Chain Risk Assessment Tool for Complex Manufacturers. Take the Assessment
Interactive Tools
Tools for understanding your requirements, risks, and our solutions.
Guides
Get up-to-date information on constantly evolving topics.
Webinars
Learn directly from experts on wide-ranging topics.
Whitepapers
Explore complex supply chain sustainability topics.
Ebooks
Keep on top of existing or emerging regulations and trends.

Knowledge Center

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Knowledge Center
Access the Assent Knowledge Center, the leading regulatory resource for supply chain management, from our team of experts.
PFAS
Per- and polyfluoroalkyl substances (PFAS)
Conflict Minerals
Deep transparency into mineral sourcing.
ESG
Environmental, social, and governance (ESG) issues.
SCDDA
Access the Assent Knowledge Center, the leading regulatory resource for supply chain management, from our team of experts.
CSRD
Streamline your reporting process to comply with the EU CSRD.
REACH
Supply chain transparency needed for compliance.
RoHS
Deep-map your supply chain to streamline compliance.
TSCA
Grow better with our TSCA compliance solution.

Blog

Blog
Read Assent’s blog for regulatory updates, supply chain sustainability advice, best practices, and more.
Supply Chain Sustainability
Learn everything you need to know about supply chain sustainability.
ESG
Discover how ESG and your supply chain are connected.
Responsible Minerals
Keep up with changing responsible minerals expectations.
Product Compliance
Get clear educational resources on key product compliance regulations.
Trade Compliance
Learn best practices for managing your trade requirements.
REACH
Get an expert breakdown of the REACH Regulation.

Events & Webinars

Training Courses

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Access comprehensive educational resources to better understand your business and regulatory requirements, and how to build your programs to mitigate supply chain risk effectively.

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