CA Prop 65

Cal EPA Office of Environmental Health Hazard Assessment 6
Proposition 65 Clear and Reasonable Warnings
Questions and Answers for Businesses Revised - August 2017
which you are providing a warning to determine if there are any applicable type size
requirements.
Consumer Product Exposure Warning Methods
Q16: What are the ways to provide safe harbor warnings for consumer product
exposures?
The safe harbor methods and content for providing a warning can be found in Sections
25602 and 25603. Section 25602(a) describes four safe harbor warning methods:
 A product-specific warning provided on a posted sign, shelf tag, or shelf sign, at
each point of display of the consumer product.
 A product-specific warning provided via any electronic device that automatically
provides the warning to the purchaser before purchase without requiring the
purchaser to seek out the warning.
 A warning on the label that complies with the content requirements in Section
25603(a); namely, the warning symbol, the signal word, “WARNING:”, and the
applicable warning message.
 An on-product “short-form” warning on the label that complies with the content
requirements in Section 25603(b); namely, the warning symbol, the signal word,
“WARNING:”, and the applicable truncated warning message. The 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 in a type size smaller than 6-point
type.
Q17: If a consumer product has exterior packaging, is a warning label required
on both the packaging and on the product itself?
No. A “label” is defined as a display of written, printed or graphic material that is affixed
to a product or its immediate container or wrapper (Section 25600.1). The warning label
should be placed in a manner to ensure that consumers receive the warning prior to
exposure. A warning must be visible on exterior packaging that is opaque if an
exposure requiring a warning can occur upon opening the package. A business may
also choose to provide a warning on both the exterior packaging and the product itself.
Q18: Can an owner’s manual be used for providing a safe harbor warning?
No. A standalone warning in an owner’s manual is not a safe harbor warning method
for consumer product exposures. For some products (specifically diesel engines,
passenger vehicles and recreational vessels), owner’s manuals are included as part of
a safe harbor warning method used in conjunction with another warning method
(Sections 25607.14, 25607.16, and 25607.18).