California Proposition 65 is a unique regulation that brings separate compliance requirements from all other regulations in the US (or abroad) and is enforced through civil litigation (via issuance of a Notice of Violation, or “NOV”). A single violation can cost a company upwards of $50,000 or more. At the beginning of each month, we take a quick look at an enforcement summary for the previous month to highlight the types of products being targeted, how frequently, and any new trends in enforcement action that may have appeared.

Hopefully these posts will raise a flag for any company selling these types of products into California so they can take a careful look at their products and get ahead of any potential enforcement!

  • Significant increase in NOV vs. September (395 vs 294), mostly tied to unleaded gasoline NOV
  • PFOA/PFOS are being targeted in a number of different consumer products (hats, bibs).
  • Service stations continue to be targeted for lack of warnings to unleaded gasoline exposures, with a huge spike last month.
  • Heavy metals in food products are constantly being targeted.
  • TiO2 and BPA NOV have dropped off for now.

 

 

RegTox helps companies address Prop 65 compliance and avoid enforcement – do not hesitate to reach out with any questions!

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