News & Analysis as of

Proposition 65

ArentFox Schiff

Prop 65 Roundup - May 2026

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In its complaint, the Personal Care Products Council argues that mandatory warnings for products containing diethanolamine constitute misleading compelled speech about risks not established in real-world product use....more

ArentFox Schiff

Prop 65 Roundup - April 2026

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Final OEHHA Report Finds Synthetic Turf Poses ‘Insignificant’ Health Risks - A final report released March 5 by California’s Office of Environmental Health Hazard Assessment (OEHHA) finds that recycled tires used as crumb...more

Perkins Coie

Cosmetics Trade Association Launches Landmark Proposition 65 Suit in California

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On March 2, 2026, the Personal Care Products Council (PCPC) lodged a major constitutional challenge to the application of Proposition 65 to a common cosmetic ingredient called diethanolamine, or DEA. ...more

Husch Blackwell LLP

How AI Is Revolutionizing Product Safety: Essential Insights for Navigating Risks, Recalls, and Regulations

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Artificial intelligence is no longer just a buzzword in product safety. AI is actively reshaping the way companies identify hazards, manage recalls, communicate warnings, and address the unique risks of lithium-ion batteries....more

ArentFox Schiff

Top Legal Issues Facing Fashion & Retail in 2026

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As in 2025, the first few months of 2026 have seen fashion and retail companies operating in an environment where legal developments increasingly shape day-to-day business decisions, and the same is expected to continue...more

Troutman Pepper Locke

Changes to California’s Prop 65 Warnings: Four Things Nicotine Product Sellers Should Know

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California recently finalized changes to its Proposition 65 (Prop 65) warning rules that included significant changes to short-form warning statements for product labels. These changes directly affect nicotine‑containing...more

Carlton Fields

[Webinar] Consumer Chemical Round Up: The Latest on State Regulation of Consumer Products and Food - March 24th, 1:00 pm - 2:00 pm...

Carlton Fields on

State-level regulation of consumer chemicals is accelerating — and diverging. More than 30 states now regulate, or are proposing to regulate, chemicals in food, packaging, and consumer products. From California Proposition 65...more

Greenberg Glusker LLP

Proposition 65 Notice Defects: Perfection Not Required

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On February 20, the California Court of Appeal issued a decision with significant implications for Proposition 65 litigation: Environmental Health Advocates, Inc. v. Pancho Villa’s, Inc., et al. In short, a private...more

ArentFox Schiff

Prop 65 Roundup - March 2026

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First Amendment Challenges Continue to Reshape Prop 65 Enforcement Landscape - Recent federal court decisions continue to affect the scope of Proposition 65 warning enforcement, particularly where compelled warnings are...more

The Food Lawyers ®

Prop 65 Food & Beverage 101: Defensive Strategies, Fictions And Facts

The Food Lawyers ® on

In most litigation, you face a known adversary on a defined battlefield and when it’s over, it’s over (e.g., a boundary dispute with an adjoining landowner). Prop 65, is entirely different: the food/beverage/supplement...more

Venable LLP

The Dietary Supplement Regulatory Uniformity Act: Key Preemption Considerations

Venable LLP on

The Dietary Supplement Regulatory Uniformity Act (H.R.7366) would amend the Federal Food, Drug, and Cosmetic Act (FDCA) to "clarify and affirm" the Food and Drug Administration's preemptive authority over dietary supplement...more

Troutman Pepper Locke

California AG Resolves Litigation Alleging Elevated Levels of Cadmium and Lead in Seafood Products

Troutman Pepper Locke on

California Attorney General (AG) Rob Bonta recently announced a consent judgment resolving allegations that the Pacific American Fish Company, Inc. (PAFCO), a seafood distributor and processor, had sold frozen seafood...more

The Food Lawyers ®

Getting Ahead Of Food Labeling Class Actions

The Food Lawyers ® on

More than three decades defending food companies in labeling class actions has made one thing abundantly clear: when a class action theory weakens, the plaintiffs’ bar doesn’t disappear; it evolves -- -- with...more

Gordon Rees Scully Mansukhani

Scope of Products Requiring Proposition 65 Warnings in California Poised to Grow

The scope of products to be drawn into the warning requirements under California’s Proposition 65 law may soon be growing. California’s Office of Environmental Health Hazard Assessment (OEHHA) requested information from the...more

Beveridge & Diamond PC

Environmental Developments to Watch in California in 2026

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California will continue to set the pace for environmental regulation in 2026, using its rulemaking, enforcement, and market influence to drive requirements that often become de facto national standards for companies doing...more

ArentFox Schiff

Prop 65 Roundup - January 2026

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ICYMI: Introducing Prop 65 Unboxed: The AFS Video Series on the Latest Prop 65 News and Trends - Our new series “Prop 65 Unboxed” brings practical insights on Proposition 65 enforcement trends, legislative updates, and...more

Bergeson & Campbell, P.C.

OEHHA Issues Information Letters Providing Prop 65 Guidance

In December 2025, the California Office of Environmental Health Hazard Assessment (OEHHA), the state agency responsible for implementing Proposition 65 (Prop 65), issued two “Information Letters” regarding Prop 65 compliance...more

Sheppard

Your Proposition 65 2025 “Wrapped”: 2025 Year in Review

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As 2025 came to a close, the Proposition 65 (Prop 65) landscape in California continued to evolve rapidly, reflecting shifting enforcement patterns, major litigation outcomes, and significant regulatory developments. This...more

Greenberg Glusker LLP

Prop. 65 Update: California Provides Clarity on BPS Warnings for Thermal Paper

Greenberg Glusker LLP on

On December 8, the California Office of Environmental Health Hazard Assessment (OEHHA), the state agency in charge of implementing Proposition 65 (Prop. 65), issued a guidance letter providing clarity about Prop. 65 warnings...more

ArentFox Schiff

Prop 65 Roundup - November 2025

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California Proposition 65 Titanium Dioxide Warning Ruled Not-Scientifically Justified by a US District Court - A US district court issued a permanent injunction preventing California from enforcing Proposition 65 warning...more

Seyfarth Shaw LLP

California Proposition 65: What In‑House Counsel Need to Know About the New Short-Term Warning Regulations

Seyfarth Shaw LLP on

California updated the Proposition 65 safe harbor warning rules, effective January 1, 2025, with a three‑year transition through January 1, 2028. The short‑form warning now must name at least one specific chemical per...more

Shook, Hardy & Bacon L.L.P.

Swiss Re releases study on the rise of nuclear verdicts in the U.S., EPA extends deadline for national perchlorate drinking water...

Monthly newsletter Material Concerns: Legal Updates on Substances of Emerging Concern keeps clients informed on the latest legal, regulatory and scientific developments related to substances of emerging concern....more

Alston & Bird

California Requests Information for Potential Listing of p,p’-bisphenol Chemicals Under Prop. 65

Alston & Bird on

There’s more to the bisphenol family of chemicals than the well-known BPA and BPS. Our Environment, Land Use & Natural Resources Group examines a California initiative to classify all p,p’-bisphenol chemicals as causing...more

ArentFox Schiff

Prop 65 Roundup - October 2025

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“California Court Ruling Endangers Public Health by Failing to Require Processed Meat on Prop 65 List of Carcinogens” Claims the Physicians Committee for Responsible Medicine - In what the Physicians Committee...more

ArentFox Schiff

Prop 65 Roundup - September 2025

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California Finally Proposes a Prop 65 Cancer Safe Harbor Level for DEA - On August 22, the California Office of Environmental Health Hazard Assessment (OEHHA) issued a proposed rule establishing a new Proposition 65...more

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