Prop 65 short-form warning

Prop 65 short-form warning content, and when §25602 lets a label use it

Direct answer. A short-form Prop 65 warning on the product label is the method in 27 CCR § 25602(a)(4): a warning that complies with the content in § 25603(b), in a type size no smaller than the largest type size used for other consumer information on the product, and in no case smaller than 6-point type. OEHHA’s final regulatory text for § 25603(b) includes the warning symbol, the word “WARNING:” or the words “CA WARNING:” or “CALIFORNIA WARNING:”, and one of the short sentences that names a chemical. If that short-form label content is used, § 25602(b) and (c) say the website or catalog may use the same content. OEHHA’s adoption notice states that the Office of Administrative Law approved the rulemaking on 26 November 2024 and that the effective date is 1 January 2025. The same final text includes earlier short-form lines for a product manufactured and labeled prior to 1 January 2028. Confirm the live Code of Regulations if either date or sentence has moved. This page quotes structure only. 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, and it does not choose short-form versus long-form for you. This page is the short-form content and method reading aid — not a determination that any SKU needs a warning.

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: short-form method before you paste a sentence

When the short-form method is the one § 25602 describes

Section 25602(a) lists methods of transmission. One of them, (a)(4), is a short-form warning on the label that complies with § 25603(b). The final regulatory text also says the entire warning must be in a type size no smaller than the largest type size used for other consumer information on the product, and in no case smaller than 6-point type. This page does not add a package-size cutoff the section does not state.

For internet purchases, § 25602(b) says a warning may be on the product display page, or behind a clearly marked hyperlink using the word “WARNING” or the words “CA WARNING” or “CALIFORNIA WARNING”, or otherwise prominently displayed before the purchase is completed. The same subsection says that if the warning uses short-form label content under § 25602(a)(4), the website may use that same content. Catalog purchases in § 25602(c) have the matching catalog sentence. The longer method list is on Prop 65 warning examples.

The final text of § 25602(b)(2) also describes a 60-calendar-day period, for internet purchases made before 1 January 2028, before a retail seller is responsible for posting an updated short-form warning after notice. Read that subsection before you treat the 60 days as covering every seller or every date.

Short-form content structure (§ 25603(b))

As written in OEHHA’s final regulatory text, a short-form warning on the label under § 25602(a)(4) includes:

The same PDF’s § 25603(c) says a product manufactured and labeled prior to 1 January 2028 may use the earlier content regardless of when the product is sold to a consumer. Those earlier lines, as written there, use “WARNING:” and a short endpoint such as “Cancer -- www.P65Warnings.ca.gov.”, “Reproductive Harm -- www.P65Warnings.ca.gov.”, or “Cancer and Reproductive Harm -- www.P65Warnings.ca.gov.” Confirm the operative subsection before you treat an older line as still in the safe harbor.

What this page is not

Related pages

Not legal advice. Confirm 27 CCR §§ 25602 and 25603, and the dates OEHHA states on its adoption notice and final regulatory text, before you treat a short-form sentence as in the safe harbor. The app displays warning content you approve.