Enforcement Summary for October 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.
Here is what we saw in October:
– acrylamide NOV jumped up again (perhaps bounty hunters are trying to get them in while they still can*);
– hexavalent chromium in leather continues to be an issue;
– BPA had a small uptick in kitchenware items;
– alcohol in kombucha is a new one!
Being targeted with an NOV can be very costly – but it is easily avoidable. 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.
*The California Chamber of Commerce filed a lawsuit against the Attorney General to stop the need for Prop 65 warnings for acrylamide in food and beverages – we will continue to follow this case.