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SGS has published a summary with examples of the California Office of Environmental Health Hazard Assessment (OEHHA) proposals to revise short form ‘clear and reasonable’ warnings under California Proposition 65 (Prop 65).


The OEHHA published a notice of modification on December 13, 2021, which, if accepted, will revise Prop 65 Article 6 ‘Clear and Reasonable Warnings – Short Form.’ These changes were first announced in a Notice of Proposed Rulemaking (NPR) issued in January 2021 and, after an extended period of public comment, the OEHHA proposed several important updates to the NPR. The intention of the revisions is to improve the short form warning by providing consumers with more specific information and also to limit the use of the safe harbor version of the warning to only small products.


The proposal:

  • Increases the maximum label size of the short-form warnings from 5 square inches (5 inches²) to 12 square inches (12 inches²). Short-form warnings may only be used if the total surface area of the label available for consumer information is less than or equal to 12 square inches, and the package shape or size cannot accommodate the full-length warning under Section 25603(a)
  • Allows the use of the short-form warning on the internet or in catalogs where the short-form warning is used on the product label
  • Provides two additional signal word options ‘CA WARNING’ or ‘CALIFORNIA WARNING’ to allow businesses to make clear that the warning is being given pursuant to California law. These are in addition to the word ‘WARNING
  • Provides additional warning language options that more directly address exposure to carcinogens or reproductive toxicants to provide an additional safe harbor warning that can be used on the product label
  • Removes the word ‘product’ from the proposed term ‘product label’ as that phrase was undefined and misleading. Instead, simply the term “label” is now being proposed


To see examples of the new short form warning labels, read SGS’s original Safeguard 169/21.


Comments on these proposed changes are being accepted until January 14, 2022, and the amendments should become operative one year after the effective date.


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 Proposed Revisions to Short Form Warnings SafeGuardS.


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For further information contact:


Dr. HingWo Tsang

Global Information and Innovation Manager

Tel: (+852) 2774 7420

Email: crs.media@sgs.com

Website: www.sgs.com/hardlines

LinkedIn: sgs-consumer-goods-&-retail


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