CA Prop 65

Cal EPA Office of Environmental Health Hazard Assessment 10
Proposition 65 Clear and Reasonable Warnings
Questions and Answers for Businesses Revised - August 2017
Section 25603, subsections (a) and (b) provide options for safe harbor warning content
for consumer products. Subsection (a) is the standard warning content, while
subsection (b) allows a business to use truncated, “short-form” warning content on a
product label. A business may use either the standard or short-form warning content on
a label for a consumer product exposure. The short-form warning cannot be used on a
sign.
Q30: Can a short-form warning be placed on the packaging or does it have to be
on the product itself?
The short-form warning can be affixed to or printed on a product or its immediate container or
wrapper.
Q31: Can a short-form warning label be used on any size product?
OEHHA’s intent in adding the short-form, truncated warning to the safe harbor methods
and content was to provide an alternative that could be used on small products or where
space was limited. There is no express prohibition, however, on using the short-form
warning on larger products. The warning content on the short-form warning must be in
a type size no smaller than the largest type size used for other consumer information on
the product label and in no case smaller than 6-point type.
Q32: If the space on a product label is too small and the short-form warning
cannot be placed in one line, can the short-form warning be placed in two/three
lines?
Yes, there is no requirement that the short-form warning content fit on one line, though
the warning must be legible.
Q33: If a business provides a short-form warning on the consumer product, can
the same warning be provided on a website?
Yes, a consumer product warning provided on a website pursuant to Section 25602(b)
can use the same short-form warning content that the business is providing on the
product. The business may also use a picture of the label on the product for the
website warning.
Warnings in Languages Other Than English
Q34: When are warnings required to be provided in languages other than
English?
Safe harbor consumer product warnings (Section 25602), environmental warnings
(Section 25604), and “tailored” warnings (Section 25607.1, et seq.) require warning
content to be provided in other languages under certain circumstances. Specifically, if a
consumer product label or packaging contains consumer information in a language
other than English, the warning must be provided in that language in addition to English.