California’s Proposition 65: What the 2025 amendments mean for your products

1. Enhanced Short-Form Warnings

• These warnings must now contain at least one specific chemical name from the Proposition 65 list, which wasn’t previously required. JD SupraSidleyBuchalterSGSCorp

• You may use “CA WARNING” or “CALIFORNIA WARNING” in place of the traditional “WARNING.” JD SupraSGSCorp

• The warning must:

  • Feature a black exclamation point inside a yellow triangle with a black outline

  • Include the signal word (“WARNING,” “CA WARNING,” or “CALIFORNIA WARNING”) in bold, all-caps

  • Contain a risk phrase plus the chemical name. The exact phrasing varies by product type. JD Supra+1OEHHA

• Minimum font size is 6-point, and the warning must appear where consumers are likely to see it. JD Supra+1

• A grace period through January 1, 2028 allows products manufactured and labeled before this date to use the older warning format. After that, all products must comply with the new requirements. JD SupraSGSCorpStinson

2. New Online Warning Obligations

• For internet and catalog sales, warnings must be presented via:

  • A warning on the product’s display page,

  • A clearly labeled hyperlink (“WARNING,” “CA WARNING,” or “CALIFORNIA WARNING”) leading to the warning, or

  • Another method that makes the warning clearly visible before purchase. JD Supra+2JD Supra+2

• If an internet retailer hasn’t received notification from a manufacturer about the need for a Prop 65 warning, they have 60 days (within the 3-year phase-in period) to update their warnings. JD SupraOEHHASGSCorp

3. Tailored Warnings for Vehicle and Marine Parts

• Motor vehicle parts (e.g., for cars, motorcycles, ATVs) that expose individuals during handling or installation must include:

  • The standard triangle symbol and bold signal word,

  • A message like:
    Handling passenger or off-highway motor vehicle parts can expose you to chemicals such as phthalates and lead, which can cause cancer and reproductive harm. To minimize exposure, service the vehicle in a well-ventilated area, wear gloves, and wash your hands. For more information see P65Warnings.ca.gov/motor-vehicle-parts. JD Supra

• Recreational marine vessel parts (e.g., for boats) require a similar warning, advising servicing in well-ventilated or outdoor areas and including a link to guidance at P65Warnings.ca.gov/marine-vessel-parts. JD Supra