California Prop 65

Assess Exposures, Check Compliance Dates and Prepare Your Next Steps

What requires action now—and what is still a proposal? That distinction is central to California Proposition 65 updates spanning new listings,proposed additions and potential warning changes.

Start with the requirements already in effect, while preparing for changes that may follow.

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Four New Cancer Listings

OEHHA’s July 17, 2026, notices identify hydrochlorothiazide, voriconazole, tacrolimus and welding fumes as additions to the cancer list.

At this time, it is important to review relevant products and operations, including process-generated welding exposures, and not just finished-product ingredients. It's also critical to obtain a product-specific legal assessment before changing pharmaceutical labeling.

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Four Proposed Listings

OEHHA’s October 9 notice proposed listing atrazine for cancer. Its October 30 notices propose listing perfluorobutanoic acid (PFBA), perfluorodecanoic acid (PFDA), and perfluorohexanoic acid (PFHxA), with related salts, for reproductive toxicity.

Atrazine is already listed for developmental and female reproductive toxicity; the cancer proposal adds an endpoint rather than introducing a new chemical.

Ask your suppliers for details on the specific PFAS covered by these proposals, check which related salts are included, and watch for final listing notices.

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Omnibus 2026 : Warning Proposals

Omnibus 2026 remains a draft, not a replacement for existing requirements. The topics include tailored warnings for certain off-road vehicle and equipment parts; short-form/full-length warning alignment; committee voting; naturally occurring chemicals; internet purchases; retailer responsibilities; QR-code warnings; and technical citation updates.

Check how warning information moves between your suppliers, retailers, and online sales channels. Get ready for possible changes, but keep following the current rules rather than switching to warning methods that are still proposals.

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Three Safe-Harbor Proposals

Adopted No Significant Risk Levels (NSRLs) provide exposure-based cancer-warning safe harbors—not ingredient-concentration limits. Other supported risk-assessment approaches remain available.

The developments to track are:

·        Vinylacetate: September 2026 pre-regulatory materials explore an NSRL and exposure-testing provisions.

·        1-bromopropane: A proposed NSRL is under rule making alongside dermal diethanolamine.

·        Diethanolamine,dermal exposure: OEHHA modified the proposal in June 2026; its route limitation should not be generalized to other exposures.

Keep the proposed levels separate from safe-harbor levels that have already been adopted. There’s also a legal development to keep in mind: the Attorney General’s enforcement page reports a June 2026 permanent injunction concerning diethanolamine cancer warnings in cosmetics and personal care products. Talk with your legal adviser about how it applies to your situation.

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Ethoprop and Bisphenol Reviews

Ethoprop is under review for possible de-listing following a change in the U.S. EPA classification underlying its listing. The Carcinogen Identification Committee is scheduled to consider its status on November 17,2026. The review by itself, does not remove the listing.

OEHHA’s May 2026 update outlines hazard-identification work on p,p′-bisphenol chemicals with the Developmental and Reproductive Toxicant Identification Committee. This listing consideration is expected in 2027. This is only preparatory work, and not a complete group listing.

Keep a record of which substitute materials you’re using, along with the evidence behind your current compliance decisions.

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Warning Dates to Know

Vinyl acetate’s warning requirement for significant exposures took effect January 3, 2026. Pending safe-harbor discussions do not postpone it.

For bisphenol S, male reproductive warnings took effect January 3, 2026; developmental warnings take effect December 8, 2026. Female reproductive warnings already apply.

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‍‍What to Do Next

Use this focused review checklist:

1.      Track status: distinguish final listings, proposals, draft amendments,safe harbors and scientific reviews.

2.      Map exposures: connect chemicals and processes to products, operations and supplier data.

3.      Document decisions: address exposure-data gaps with technical and legal input.

4.      Audit warnings: check packaging, online listings and retailer communications.

5.      Assign ownership: monitor final notices, effective dates and legal developments.

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Collecting supplier declarations can be challenging when you manage a large supply chain and a high product or part count. We can help you assess your collection process and identify where a supplier checklist, a questionnaire, or automation support may be helpful. Contact us to discuss your needs and explore an approach that fits your team and supply chain.

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The Bottom Line

It's time to assess your exposures, check applicable compliance dates, and assign clear next steps—addressing current obligations while preparing for potential changes.

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Turn California Proposition 65 requirements into a practical action plan. From training and gap assessments to compliance program development and supplier data collection, we help you build your team’s knowledge, identify gaps and document your due diligence. Contact us today to discuss the right support for your business.

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Get a BlueCircle Advisors Quote Today

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Links

OEHHA — Proposition 65 Notices

California Proposition 65Warnings — Chemicals

OEHHA— Proposition 65: Omnibus 2026 Pre-Rulemaking

OEHHA— Topics of Proposed Regulatory Changes in Omnibus 2026

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