Q.01

What does a Prop 65 warning need to say?

A safe-harbor Prop 65 warning needs four things: the warning symbol, a signal word, a statement naming at least one listed chemical, and the type of harm (cancer, reproductive harm, or both). Under the amendments in effect since January 1, 2025, short-form warnings must also name a chemical.

Approach: The datasets I can search hold OEHHA's Proposition 65 chemicals list but not the warning regulations. This answer therefore comes from search snippets of OEHHA's official pages (oehha.ca.gov and P65Warnings.ca.gov), not the full regulation text of Title 27 CCR Article 6.

Full-length consumer product warning (27 CCR §25603(a))

  • Symbol: in most cases, a triangle with a bold black outline. It can be printed in black and white if the label, sign or shelf tag isn't printed in yellow.
  • Signal word: "WARNING", "CA WARNING" or "CALIFORNIA WARNING".
  • Content: this depends on how the chemical is listed.
    • Reproductive toxicant: "This product can expose you to chemicals including [name of one or more chemicals], which is [are] known to the State of California to cause birth defects or other reproductive harm."
    • Both a carcinogen and a reproductive toxicant: "...which is [are] known to the State of California to cause cancer and birth defects or other reproductive harm."
    • Carcinogen only: the same wording, ending with "to cause cancer".
  • Chemical name: to rely on the safe harbor content, the warning must name at least one chemical (§25601(b), §25603).

Short-form label warning (§25603(b)/(c))

  • Rulemaking: OAL approved it on November 26, 2024, and it took effect January 1, 2025. It amended §§25601, 25602, 25603 and 25607.2 and added §§25607.50 to 25607.53.
  • Chemical name: the short form must now name at least one chemical for each endpoint. If one chemical is listed for both cancer and reproductive harm, naming that chemical alone is enough.
  • Example wording from OEHHA's samples:
    • "Cancer risk from exposure to [name of chemical]. See www.P65Warnings.ca.gov."
    • "Risk of cancer and reproductive harm from exposure to [name of chemical]."
    • Alternative: "Can expose you to [name of chemical], a carcinogen and reproductive toxicant."
  • Transition: businesses have three years to move to the new short form. Products manufactured on or after January 1, 2028 need the symbol, the signal word in §25603(b)(2) and the content in §25603(b)(3) to get safe harbor protection.
  • Online sales: retailers have 60 days to update online short-form warnings after a manufacturer notifies them.
  • Other uses: the rule says explicitly that short-form warnings can be used for food. It also adds tailored warnings for vehicle parts and recreational marine vessel parts.

Where the warning goes: how the warning is delivered (on-product label, shelf sign, online, catalogue) is covered separately in §25602. Some sectors have their own tailored warnings, for example food, wood dust, environmental exposures, and bisphenol A in canned and bottled foods and beverages (§25603.3).

I can look up a chemical on the Prop 65 list next, to confirm whether it's listed for cancer, reproductive toxicity or both and which wording applies.

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Q.02

Can I use the short-form warning?

Probably yes. Under the rule in effect since January 1, 2025, the short-form warning isn't limited to small packages. OEHHA's rulemaking documents say it may be used "on any size product" as long as it meets the type-size and placement rules. The main conditions are that it goes on the product label itself and is printed in at least 6-point type.

Approach: The datasets I can search don't hold the Prop 65 warning regulations (Title 27 CCR Article 6), only OEHHA's chemicals list. This answer therefore comes from search snippets of OEHHA's official rulemaking documents and the P65Warnings.ca.gov FAQ.

Conditions for using the short form

  • Placement: it must be on the product itself or its immediate packaging, meaning the label, immediate container or wrapper. It's an on-product label option, not a method for shelf signs.
  • Type size: at least 6-point. The amended rule removed the old requirement that the warning be no smaller than the largest type used for other "consumer information" on the product. A business can now choose any size of 6-point or larger.
  • Conspicuousness: it must still meet §25601(c). The warning must be displayed prominently enough that it's likely to be seen and understood.
  • Content: it must name at least one listed chemical for each endpoint, as covered in the previous answer. Products made on or after January 1, 2028 must use the new short-form content to keep safe harbor protection.
  • Food: the amended rule says explicitly that the short form can be used for food products.

What changed in the rulemaking

  • Label-size limit dropped: a 2021 OEHHA proposal would have allowed the short form only where the labelling surface was 5 square inches or less and couldn't fit the full-length warning. After comments called this impractical, OEHHA dropped the size limit from the version it went on to adopt.
  • Older guidance: some OEHHA documents still describe the 5-square-inch limit or the "largest consumer information type size" test. Those reflect superseded proposals or the pre-2025 text.

When the full-length warning is needed instead

  • Off-product warnings: if the warning isn't on the product or its immediate packaging (for example a shelf sign or a separate tag), use a full-length warning under §25603(a).
  • Type too small: the same applies if you can't print the short form in at least 6-point type.

OEHHA has posted a 2026 omnibus regulatory text. I couldn't tell from the search results whether it changes the short-form rules.

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Q.03

What about products sold online?

Online sales need two warnings. The product still has to carry its own warning, on the product or its packaging, when it's delivered. The website also has to show a warning before the buyer completes the purchase (27 CCR §25602(b)). The online warning can use the short form, but only if the short form is what's printed on the product.

Approach: The datasets I can search hold OEHHA's Proposition 65 chemicals list but not the warning regulations. This answer comes from search snippets of OEHHA's official rulemaking documents and the P65Warnings.ca.gov business FAQs, not the full text of the regulation.

How to show the online warning (any one of these)

  • Product page: put the warning on the product display page.
  • Hyperlink: use a clearly marked link labelled "WARNING" that leads to the warning text.
  • Other prominent display: any other way of showing it prominently before the purchase is completed. OEHHA's example is a pop-up that appears when the buyer enters a California zip code.
  • Not acceptable: a warning the buyer has to go looking for doesn't count as "prominently displayed".

Using the short form online

  • Matching the label: the website can repeat the short-form text that's on the product, or show a picture of the product label.
  • Mismatch: if the product carries a full-length warning, the website needs the full-length content too.
  • Updates: under the rules in effect since January 1, 2025, a retailer has up to 60 calendar days to show a manufacturer's updated short-form warning online.
  • Chemical name: the online short form must name the chemical, the same as the label does under the new content rules.

Catalogue sales (for comparison)

  • On the product: the product must still carry a warning using one of the consumer-product methods.
  • In the catalogue: the catalogue warning must be placed so it's clearly linked to the item being bought.

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Q.04

Is it different for food?

Yes, food has its own tailored warning rules. The content follows §25607.2, the wording starts "Consuming this product can expose you to…", and it points to www.P65Warnings.ca.gov/food. On a food label, the warning must be set off from the surrounding information and enclosed in a box. Since January 1, 2025, the short-form warning can also be used on food labels.

Approach: The datasets I can search hold OEHHA's Proposition 65 chemicals list but not the Title 27 CCR Article 6 warning regulations. This answer comes from search snippets of OEHHA's rulemaking documents and the P65Warnings.ca.gov sample-warning pages, not the full text of the regulation.

How food differs from other consumer products

  • Content: food uses its own wording under §25607.2, not the general §25603 text.
    • Full-length, carcinogen: "WARNING: Consuming this product can expose you to [name of chemical], which is known to the State of California to cause cancer. For more information go to www.P65Warnings.ca.gov/food."
    • Full-length, both endpoints: "…known to the State of California to cause cancer and [name of one or more chemicals], which is [are] known to the State of California to cause birth defects or other reproductive harm."
  • Boxed on the label: an on-label food warning must be set off from other information and enclosed in a box. This is not a requirement for the general consumer-product warning.
  • Signal word: "WARNING:", "CA WARNING:" or "CALIFORNIA WARNING:", in bold capital letters.
  • Symbol: OEHHA's guidance describes the yellow triangle symbol for consumer product warnings. The official pages I found don't say whether food warnings need it, so I can't confirm the food rule on the symbol.
  • Where the warning goes: besides the label, a food warning can be given on a posted sign, shelf tag or shelf sign at each point of display.

Short form for food

  • History: OEHHA says it didn't expect the short form to be used on food when it wrote the 2016 rules. The amendments in effect since January 1, 2025 explicitly allow it.
  • Format: the food short form must keep the food-specific features, including the box and the bold signal word. It points to the /food web address.
  • Example wording:
  • Chemical name: the short form must name a chemical, the same as for other products.

Other food-specific options

  • Acrylamide: foods that expose consumers to acrylamide have their own tailored safe-harbor warning. OEHHA added another option for it in a 2024 rulemaking, alongside the general full-length and short-form food warnings.
  • Restaurants: food and beverages served in restaurants use a separate tailored sign. One option is an 8½ × 11 inch sign in at least 28-point type at each public entrance.
  • Canned and bottled foods and beverages: bisphenol A exposure from these is covered by §25603.3, as noted in the first answer.

Online food sales: the official sources I found don't describe a separate internet rule for food. The online requirements from the previous answer come from the general consumer-product methods. I didn't find an official source saying whether they apply unchanged to food sold online.

I can look up a chemical on the Prop 65 list next, to confirm whether it's listed for cancer, reproductive toxicity or both, which decides the food wording.

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Q.05