Proposition 65 Enforcement Summary – September 2019
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”). 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 appear.
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 action.
Thoughts on what we saw:
– drop in overall NOV issued (163 vs. 216 in Aug.);
– significant drop in acrylamide targets (3 vs. 31 in Aug.);
– hexavalent chromium is back on the radar for leather products;
– all the same issues for phthalates (in consumer products such as bags/cases, tools etc.) and heavy metals (dietary supplements, food).
Being targeted with an NOV can be very costly – but it is easily . Get ahead of the curve by talking with our experts before you are targeted with enforcement action! It’s free to chat and you will be glad you did.
