CA Prop 65

Cal EPA Office of Environmental Health Hazard Assessment 8
Proposition 65 Clear and Reasonable Warnings
Questions and Answers for Businesses Revised - August 2017
(a)(1)-(4). In addition, if an on-product (short-form) warning is provided on the product
label, the catalog warning may use the same content.
Q23: Instead of displaying the entire consumer product warning content on the
product page of a catalog or webpage, can a business place the warning symbol
next to the product and use it as a reference to a full consumer product warning
provided elsewhere in the catalog or website and still claim safe harbor
protection?
No. A warning symbol provided near a product in a catalog or on a webpage separate
from a consumer product warning which is located elsewhere in the catalog or website
is unlikely to ensure that the warning is “clearly associated” with the item being
purchased. This approach would not meet the safe harbor requirements in the
regulations.
Consumer Product Exposure Warning Content
Warning Symbol
Q24: Which American National Standards Institute (ANSI) International
Organization for Standardization (ISO) number is required for the yellow warning
symbol?
The Article 6 regulations did not adopt the ANSI standards for warning symbols, and
there is no requirement that the warning symbol color correspond to a specific ISO
number. The regulations only require that the warning symbol be “yellow.” OEHHA
provides sample compliant warning symbols that a business may download and use.
Q25: If a business does not have the ability to print in color, can the business
print the warning symbol in black and white?
Yes, if a business does not use the color yellow for other information printed on the
label or sign, the business may print the warning symbol in black and white (Section
25603(a)).
Type Size
Q26: What is the minimum type size for consumer product exposure warnings?
For a consumer product exposure safe harbor warning provided on a label pursuant to
Section 25602(a)(3), there is no specific type size requirement. Section 25601(c),
however, requires that safe harbor consumer product exposure warnings on a label be
prominently displayed with such conspicuousness as compared with other words,
statements, designs or devices on the label, labeling, or sign, as to render the warning
likely to be read and understood by an ordinary individual under customary conditions of
purchase or use.