Prop 65 lead warning
When a Prop 65 warning for lead may be needed, and the name the warning must use
Direct answer. A Prop 65 warning for lead may be needed when a business knowingly and intentionally exposes a person to lead and no exemption in the statute applies. OEHHA’s Lead page lists Lead for developmental toxicity, male reproductive toxicity, and female reproductive toxicity (each listed 02/27/1987), and its note says Lead and lead compounds is the cancer listing. That page publishes an oral no-significant-risk level (NSRL) of 15 µg/day and a maximum allowable dose level (MADL) of 0.5 ug/day, and says both are for Lead. OEHHA’s final regulatory text for 27 CCR § 25603 says a safe-harbor warning includes the name of one or more listed chemicals, and that a warning for both cancer and reproductive toxicity must name one or more chemicals for each endpoint unless the named chemical is listed for both. Confirm the live list before you treat one word as covering both listing names. This page does not decide that any product needs a warning. It is not legal advice.
Prop 65 Warning Manager (Shopify App Store · Write a review) displays California Prop 65 warnings on product pages and keeps an audit trail of warning edits, assignments, and storefront activation events. Every warning needs merchant approval before it goes live. The app does not decide whether an exposure requires a warning. This page is the lead-list and chemical-name reading aid — not a determination for any SKU.
Related: CLPLens — Hazard pictograms on the product page, not only the parcel.
Free check first: Prop 65 warning question check runs in your browser and sends nothing. Describe a product and see which list names and 27 CCR warning rules to read.
Checklist before you treat lead as in or out of a warning
- Read the live Lead and Lead and lead compounds pages, not a stored copy of this one.
- Read Health and Safety Code § 25249.6 (the warning duty) and § 25249.10 (exemptions) on the official California code.
- Quote safe-harbor numbers only from the OEHHA page you opened. If a route or a compound is not on that page, see OEHHA.
- For the warning sentence, use the listed chemical name for the endpoint you are warning about. Walk the sentence shapes on Prop 65 warning examples and the short-form warning.
- Other exemptions, including fewer than 10 employees, are a separate reading. That page is Prop 65 with fewer than 10 employees.
When a warning may be needed
Proposition 65 is the Safe Drinking Water and Toxic Enforcement Act of 1986. The warning duty is a knowing and intentional exposure to a listed chemical without a clear and reasonable warning, subject to the exemptions the statute states. Presence of lead in a material is not, by itself, the test this page can apply. OEHHA publishes safe-harbor levels; an exposure at or below the level OEHHA set for that endpoint is the kind of showing the statute’s exemption is written around. How to measure an exposure — which route, which medium, which user — is on OEHHA’s materials, not on this page. See OEHHA.
OEHHA’s Lead page, as read for this guide, shows:
- Reproductive toxicity: currently listed, as developmental toxicity, male reproductive toxicity, and female reproductive toxicity, each with a date of listing of 02/27/1987.
- No Significant Risk Level (NSRL) — Oral: 15 µg/day.
- Maximum Allowable Dose Level (MADL): 0.5 ug/day.
- Note on that page: listed as Lead for developmental and reproductive effects; listed as Lead and lead compounds for cancer. NSRL and MADL are for Lead.
The units above are copied as that page prints them (µg for the oral NSRL, ug for the MADL). Lead acetate, lead phosphate, and lead subacetate are separate listings; the same note says their NSRLs are molecular-weight adjustments of the NSRL for Lead. This page does not reprint those adjusted numbers. See OEHHA.
What the warning must name
OEHHA’s final regulatory text for 27 CCR § 25603 says a warning meets that subarticle if it includes the name of one or more of the listed chemicals for which the warning is being provided. Where the warning is for more than one endpoint (cancer and reproductive toxicity), the warning must include the name of one or more chemicals for each endpoint, unless the named chemical is listed as known to cause both cancer and reproductive toxicity. The long-form and short-form sentence shapes that carry that name are on Prop 65 warning examples and the short-form warning. This page does not paste a finished warning.
Because the Lead page uses two listing names, a single word may not be the listed name for both endpoints. Confirm the live chemical pages, and the live § 25603 text, before you drop either name.
What this page is not
- Not legal advice, an exposure assessment, or a decision that a SKU needs a warning.
- Not a substitute for the live OEHHA list, the Health and Safety Code, or 27 CCR.
- Not the safe-harbor sentence gallery. That URL is Prop 65 warning examples.
- Not the short-form method and cutover dates. That URL is Prop 65 short-form warning.
Related pages
- Prop 65 warning question check — which list names and 27 CCR rules to read
- Prop 65 warning examples — § 25602 methods and long-form structure
- Prop 65 short-form warning — § 25603(b) content
- OEHHA: Lead
- OEHHA: Lead and lead compounds
- OEHHA final regulatory text (PDF)
- Prop 65 Warning Manager — live App Store listing
- Shopify apps hub
- Tools
Not legal advice. Confirm the OEHHA chemical pages, Health and Safety Code §§ 25249.6 and 25249.10, and 27 CCR § 25603 before you treat a lead exposure as in or out of a warning. The app displays warning content you approve. It does not decide whether a warning is required.