Compliance
Proposition 65 compliance
California’s warning law reaches well beyond California. If you sell into the state, including through marketplaces, here is what applies to you, and how we help you get the label right.
Two questions
Does Prop 65 apply to you?
Question one
Do you operate a company with 10 or more personnel?
Question two
Do you sell or plan to ship the products we produce for you to consumers in California?
This includes sales made through online retailers and marketplaces.
If your answer to both is yes
You are required by law to display certain warnings on your products, where applicable. California’s Prop 65 warning format, effective since September 1, 2018, must describe the chemicals in the product and the potential harm they may cause. A generic “risk of cancer, birth defects, or reproductive harm” is no longer sufficient under the current law.
If your company meets the above criteria, we can help you format the warnings to your product.
The warning labels
The exact wording the law requires
These are the safe-harbor warnings set out in Title 27, California Code of Regulations, Section 25603, current as of 2025. A warning that follows one of these formats is deemed clear and reasonable.
Every warning needs three parts: the yellow triangle symbol, the warning word, and the message. The warning word may be WARNING:, CA WARNING: or CALIFORNIA WARNING:, always in bold capitals. The symbol sits to the left of the text and is never smaller than the height of the word WARNING.
Standard warning: carcinogen
§ 25603(a)(2)(A)
WARNING: 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 cancer. For more information go to www.P65Warnings.ca.gov.
Standard warning: reproductive toxicant
§ 25603(a)(2)(B)
WARNING: 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. For more information go to www.P65Warnings.ca.gov.
Standard warning: both, from different chemicals
§ 25603(a)(2)(C)
WARNING: 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 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. For more information go to www.P65Warnings.ca.gov.
Standard warning: one chemical listed as both
§ 25603(a)(2)(D)
WARNING: 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 cancer and birth defects or other reproductive harm. For more information go to www.P65Warnings.ca.gov.
Where the warning covers a single chemical, the words “chemicals including” may be deleted from formats (A), (B) and (D), and “which is [are] known” becomes “which is known.” The symbol is a black exclamation point in a yellow equilateral triangle with a bold black outline; it may be printed in black and white only where the label, sign or shelf tag is not printed using the color yellow.
Short-form warnings
The label version, now with a chemical name
The short-form option was amended effective January 1, 2025. It now has to name the chemical. Products manufactured and labeled before January 1, 2028 may keep using the old wording for as long as they are sold; new labels after that date must use one of these.
Each short-form warning still needs the yellow triangle symbol and the warning word (WARNING:, CA WARNING: or CALIFORNIA WARNING:) in bold capitals, followed by one of the options below.
Carcinogen
§ 25603(b)(3)(A)
Cancer risk from exposure to [name of chemical]. See www.P65Warnings.ca.gov.
Can expose you to [name of chemical], a carcinogen. See www.P65Warnings.ca.gov.
Reproductive toxicant
§ 25603(b)(3)(B)
Risk of reproductive harm from exposure to [name of chemical]. See www.P65Warnings.ca.gov.
Can expose you to [name of chemical], a reproductive toxicant. See www.P65Warnings.ca.gov.
Both, from different chemicals
§ 25603(b)(3)(C)
Risk of cancer from exposure to [name of chemical] and reproductive harm from exposure to [name of chemical]. See www.P65Warnings.ca.gov.
Can expose you to [name of chemical], a carcinogen, and [name of chemical], a reproductive toxicant. See www.P65Warnings.ca.gov.
One chemical listed as both
§ 25603(b)(3)(D)
Risk of cancer and reproductive harm from exposure to [name of chemical]. See www.P65Warnings.ca.gov.
Can expose you to [name of chemical], a carcinogen and reproductive toxicant. See www.P65Warnings.ca.gov.
The legacy short form, good until 2028
A product manufactured and labeled before January 1, 2028 may carry the older short form for as long as it is sold, regardless of when it reaches a consumer. Here the warning word must be WARNING:; the CA and CALIFORNIA variants are not offered for this legacy format.
Carcinogen
§ 25603(c)(2)(A)
Cancer -- www.P65Warnings.ca.gov.
Reproductive toxicant
§ 25603(c)(2)(B)
Reproductive Harm -- www.P65Warnings.ca.gov.
Both
§ 25603(c)(2)(C)
Cancer and Reproductive Harm -- www.P65Warnings.ca.gov.
Bracketed placeholders stand in for the specific listed chemical your product is warned for. Which warning applies to your product, and which chemical has to be named, depends on your formula and your testing. We will help you determine and format it. This page summarizes the safe-harbor regulations and is not legal advice; the controlling text is Title 27, California Code of Regulations, Article 6, published by OEHHA.
Context
Stricter than federal standards
“Prop 65” warnings are required exclusively under California law and only need to be displayed on products sold to consumers in the state of California. Health Genesis Corporation is confident the naturally occurring chemicals in its supplements are safe and believes they should be exempt from this requirement; however, providing such warnings is the only way to comply with Prop 65. These standards are some of the most stringent in the nation, far exceeding federal or international standards.
- More than 800 substances fall under the regulation
- Lead, mercury and other elements occur naturally in air, soil and water
- A warning is not a statement that a product is unsafe
Questions
What brands ask us most
What products require warnings?
California Prop 65 encompasses more than 800 substances. Any product that may contain these substances requires a Prop 65 warning. The list includes pesticides, heavy metals, and even certain levels of vitamin A. Chemicals such as lead are prevalent in the environment, including naturally in the air, soil, and water. As such, some of these chemicals are common in the food supply, although they are not deliberately added to foods, beverages, or dietary supplements.
Should I be worried?
It is important to pay attention to all product warnings. However, a Prop 65 warning does not mean that a product is unsafe, nor does it mean the product will cause health issues when it is used as recommended. A chemical listed under Prop 65 could be linked to animal studies, as Prop 65 standards are among the most stringent in the country. The warning level for reproductive toxins, for instance, is 1,000 times lower than the lowest level at which animal studies indicated no negative health effects.
Also of note is that in most cases, California product label warning requirements differ from federal safety requirements. This causes certain discrepancies between the labels of products sold in California and those required in other U.S. states. For example, you may see a Prop 65 warning label on a product sold in California and no warning on the same product sold elsewhere. These products are not different in any way; the reason for this is that Prop 65 warnings are required exclusively in sales to customers in California.
Who decided on these warnings?
The state of California adds substances to the Prop 65 list via a formal process. Substances may be listed in a number of ways, for instance in response to reports based on animal studies. Often, animal studies feature high dosages of chemicals or other substances.
What substances are involved in Prop 65?
A significant amount of dietary supplements feature substances that require a warning under California law. Even a certain level of vitamin A requires a Prop 65 warning. In addition, naturally occurring lead and mercury require warnings above a certain level, even if they aren’t added deliberately to the product in question.
How do California Prop 65 warnings compare to federal warnings?
A number of substances require a Prop 65 warning at a much lower level than federal action limits. For example, the California Prop 65 warning standard for lead is 0.5 micrograms per day. This is significantly lower than the Environmental Protection Agency’s (EPA) limit of 15 micrograms per liter. Approximately a quarter-cup of the water deemed safe by the EPA on a federal level would bring you over the safe daily limit of lead consumption according to Prop 65 in California.
Let us help you format the warning
Send us your product and market details and our compliance team will help you apply the correct Prop 65 language to your label.
For more information on Prop 65, visit California’s Office of Environmental Health Hazard Assessment.
