Question 1

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

Accepted Answer

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.

Question 2

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

Accepted Answer

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.

Question 3

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

Accepted Answer

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.

Question 4

Can I purchase generic revised short-form warning labels?

Accepted Answer

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.

Question 5

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

Accepted Answer

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

Question 6

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

Accepted Answer

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

Question 7

What is supply chain sustainability management (SCSM)?

Accepted Answer

Supply chain sustainability management (SCSM) is a proactive approach to achieving long-term sustainability and reducing risks in manufacturing supply chains. It focuses on transparency; compliance with environmental, social, and governance (ESG) requirements; and encouraging responsible sourcing practices.

Question 8

Why is a continuous focus on SCSM critical?

Accepted Answer

Supply chain sustainability is a continuous journey and not a one-time effort. Companies need to commit to ongoing improvement and regularly reassess their strategies to keep up with evolving challenges. A new supplier, new regulation, or new customer can introduce a new set of sustainability risks that may require new processes. An outdated (or stagnant) program can put you at risk of falling out of compliance when new substances are added to a regulation, or impact your ESG rating.

Question 9

Why is SCSM important for businesses today?

Accepted Answer

Supply chain sustainability management is vital because of increasing regulatory requirements, customer expectations, and competitive pressures. It helps manufacturers mitigate risks like compliance penalties, supply chain disruptions, and reputational damage while enabling better data-driven decisions and maintaining operational continuity.Supply chain sustainability management must be integrated into the core business strategy and operations. This includes setting measurable goals, tracking progress, and making supply chain sustainability a reportable key performance indicator for the company.

Question 10

What role do leaders and executives play in SCSM?

Accepted Answer

Supply chain sustainability management is not just the realm of compliance and sustainability professionals. Leadership plays a pivotal role in your SCSM program too. Executives must champion sustainability initiatives and embed this value at all levels of the organization.Many companies make ambitious sustainability commitments, but struggle to implement the necessary changes to achieve them without leadership buy-in. Leaders can help an SCSM program overcome factors like lack of internal resources, difficulties in planning, and internal resistance to change.

Question 11

What are the benefits of implementing SCSM?

Accepted Answer

Supply chain sustainability management provides numerous advantages, including:Protection against compliance penalties and reputational risksIncreased supply chain transparencyScalability to adapt to new regulations and goalsEnhanced product compliance and sustainabilityCompetitive edge through proactive sustainability practices

Question 12

Why is transparency vital in an SCSM program?

Accepted Answer

Regular, honest updates about supply chain sustainability help build trust with your stakeholders and demonstrate a genuine commitment to sustainability. That means your organization needs to be open about successes and failures. Communication with stakeholders is key; engaging stakeholders and customers in two-way conversations helps you understand their expectations.Aligning actions with stated commitments is important to help you avoid greenwashing. Greenwashing is when companies overstate or misrepresent their sustainability efforts to artificially boost their brand. Being accused of greenwashing not only damages your reputation but also erodes public trust in sustainability initiatives more broadly.

Question 13

How can businesses begin implementing SCSM?

Accepted Answer

Evaluate priorities and stakeholders: Define specific goals and regulations that must be addressed.Enable suppliers: Provide training and resources for accurate data sharing.Collect and manage supply chain data: Use automated tools to gather and analyze relevant information.Monitor regulations proactively: Stay ahead of new and changing compliance requirements.

Question 14

What risks do companies face without SCSM?

Accepted Answer

Without SCSM, businesses risk:Compliance penalties due to regulatory violationsSupply chain disruptions from unforeseen sustainability issuesLosing customers and market share due to poor sustainability practicesReputational damage from forced labor, hazardous chemicals, or ESG non-compliance in their supply chains, among other risks

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Tag: Product Compliance