Short-Form Warning (Post-January 2025)

A short-form warning is an abbreviated Proposition 65 safe harbour warning format originally intended for small product packaging. OEHHA’s December 2024 amendments (finalized December 6, 2024, effective January 1, 2025) significantly updated the short-form warning requirements under Title 27 CCR §25603(d) and §25607.2. Key changes: (1) the short-form warning must now include the name of at least one listed chemical for each health risk endpoint (cancer and/or reproductive toxicity); (2) the warning can now be any size packaging (the previous small-package restriction has been removed); (3) the warning must use a 6-point font minimum and the Prop 65 warning symbol; (4) alternative signal words ‘CA WARNING’ or ‘CALIFORNIA WARNING’ are now permitted. A three-year transition period runs until January 1, 2028; products manufactured before that date with prior short-form warnings may continue to be sold.

Title 27 CCR §25603(d) and §25607.2 (short-form warning regulations); OEHHA amendments approved November 26, 2024, effective January 1, 2025; 3-year transition period to January 1, 2028.

The January 2025 short-form warning amendments are the most significant change to Proposition 65 warning requirements since 2018. Businesses currently using short-form warnings without chemical names must now determine: (1) which listed chemicals are present in their products above safe harbour levels; (2) which chemical name(s) to include in the new short-form warning; and (3) how to update product labels, online warnings, and marketing materials. The transition period allows products manufactured before January 1, 2028 with the old short-form format to continue being sold, but new labels should use the new format as soon as practicable.