UNITED STATES / CHEMICAL EXPOSURE AND WARNINGS

Understand exposure.
Communicate with clarity.

Assess California Proposition 65 at the level that matters: potential human exposure. Connect chemical screening, use conditions and warning decisions, with consistent information across product packaging, online sales and the supply chain.

Product assessment · Documentation · Coordination
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CHEMICAL EXPOSURE AND WARNINGS
United States
SERVICE AT A GLANCEProp 65 ComplianceUnited States

YOUR MARKETUnited States

YOUR FOCUSChemical exposure and warnings

OUR APPROACHConnected compliance support

A craftsperson working with materials in a workshop
FROM THE DETAILSTo the
possibilities.
CLARITY AT EVERY STEP
Built around your product.
Focused on your next market.

01 / THE BIG PICTURE

Understand the requirements.
See the opportunity.

California Proposition 65 concerns exposure to listed chemicals associated with cancer or reproductive harm and restrictions on discharges into drinking-water sources. For consumer products, the key question is whether a warning is required for the anticipated exposure, not simply whether a laboratory detects a listed substance.

There is no official Proposition 65 product approval certificate. A defensible approach combines knowledge of the product, relevant chemical information and a documented exposure or warning decision. The assessment should remain specific to the marketed construction and foreseeable use.

Explore the requirements

02 / WHERE IT APPLIES

Different products.
A shared focus on compliance.

Start with your product’s intended use and category. Here are some of the applications covered in this service.

APPLICATION 01

Consumer materials

Screen accessible plastics, metals, coatings and formulations.

APPLICATION 02

Food-contact products

Consider relevant transfer and use-related exposure evidence.

APPLICATION 03

Furniture and household goods

Connect material information with the actual exposure scenario.

These are examples. The applicable route depends on your product specifications and target market.

03 / THE PATH FORWARD

From assessment
to your next market.

Move from the first assessment to a documented compliance plan, with clear responsibilities and evidence for your product.

01

Screen intelligently

Identify plausible listed chemicals and evidence gaps.

02

Assess exposure

Connect test data with product use and relevant levels.

03

Decide communication

Document the warning or no-warning basis.

04

Maintain consistency

Align channels, partners and future product changes.

One connected workflow, with your product at the center.

Create your product brief

04 / EXPLORE THE DETAILS

Your requirements.
The details, made clear.

Open a topic for guidance on scope, requirements, documentation and practical considerations.

6 topics in this guide

CHAPTER 01Identify relevant chemicals and materialsReview the current OEHHA list against materials, formulations and production information. Focus on plausible chemical sources…

Review the current OEHHA list against materials, formulations and production information. Focus on plausible chemical sources rather than testing every product for an undifferentiated list. Supplier documentation can guide targeted analysis, but its scope must match the component, formulation and revision actually supplied.

  • Distinguish a chemical’s presence from the exposure it may create.
CHAPTER 02Describe realistic exposure conditionsDefine who uses the product, how frequently, for how long and through which routes exposure may occur. Consider the accessible…

Define who uses the product, how frequently, for how long and through which routes exposure may occur. Consider the accessible material and its behaviour during expected use. Concentration results alone do not establish daily exposure; an assessment may require migration, release or other use-specific information.

  • Document assumptions so a technical reviewer can reproduce the reasoning.
CHAPTER 03Assess safe-harbour or other evidenceOEHHA publishes safe-harbour exposure levels for some listed chemicals. These are not universal concentration limits for…

OEHHA publishes safe-harbour exposure levels for some listed chemicals. These are not universal concentration limits for materials. Where a relevant level is absent, the business may need another properly supported assessment of the anticipated exposure. Review the applicable exemption and evidence before deciding a warning is unnecessary.

  • Keep the chemical endpoint and exposure route visible in the assessment.
CHAPTER 04Select an appropriate warning approachWhen a warning is needed, review the current rules for its content and delivery method. Requirements differ across product and…

When a warning is needed, review the current rules for its content and delivery method. Requirements differ across product and exposure contexts. Updated short-form warning provisions took effect in 2025 with a transition period; existing artwork should therefore be checked against the applicable manufacture and implementation provisions.

  • Coordinate physical labels with internet and catalogue warnings.
CHAPTER 05Coordinate the commercial supply chainAgree how chemical and warning information passes from manufacturer to importer, distributor and retailer. Identify who controls…

Agree how chemical and warning information passes from manufacturer to importer, distributor and retailer. Identify who controls online listings and private-label artwork. A warning supplied in a technical email will not help customers if the retail team cannot associate it with the correct model and sales channel.

  • Retain approved wording and evidence of notification to relevant partners.
CHAPTER 06Revisit the decision when conditions changeTrack formulation changes, supplier substitutions, new intended uses and list updates. A decision for one exposure scenario…

Track formulation changes, supplier substitutions, new intended uses and list updates. A decision for one exposure scenario should not automatically be applied to a different product format. Keep the screening rationale, analytical data, assessment and warning decision together so future reviews start from a clear record.

  • Avoid both unsupported no-warning claims and unnecessary blanket warnings.

Requirements vary by product, intended use and market. Confirm the applicable standards and current regulatory route before proceeding.

05 / A LITTLE MORE CLARITY

Your questions.
Our starting points.

Practical answers to common questions about Prop 65 Compliance.

01Does detecting a listed chemical always require a warning?

No. The applicable exposure and legal provisions must be assessed; presence alone is not the complete decision.

02Is there a universal Prop 65 pass limit?

No. Safe-harbour values concern exposure and vary by chemical and endpoint.

03Can a warning replace other product safety duties?

No. Proposition 65 warnings do not establish compliance with other restrictions or safety requirements.

04Should old short-form labels be reused unchanged?

Review the amended rules and transition provisions before relying on existing artwork.

LET’S PLAN WHAT’S NEXT

Your product.
A world of potential.

Turn your product details and ambitions into a clear starting point.

Create my product brief

Service marks and organization names identify the standards and regulatory topics discussed. They do not indicate certification of, affiliation with, or endorsement of Complise Global.