California Prop 65 in 2026: Is Your Supply Chain Ready for the New Warning Requirements?
- Georgie Whitehouse
- Dec 18, 2025
- 3 min read
If you sell products in California, "Proposition 65" is likely a phrase that keeps your compliance team up at night. Officially known as the Safe Drinking Water and Toxic Enforcement Act of 1986, this regulation is far more than just a label, it is a dynamic, high-risk compliance hurdle that evolves constantly.
With significant updates hitting in January 2026, specifically regarding short-form warnings, the margin for error has arguably never been slimmer.
In this guide, we’ll break down what’s changing, why the risk of "bounty hunter" lawsuits is rising, and how GoCompliance can help you automate your way to safety using our all-inclusive platform.
What is California Proposition 65?
Proposition 65 requires businesses to provide "clear and reasonable" warnings to Californians about significant exposures to chemicals that cause cancer, birth defects, or other reproductive harm.
The state maintains a massive list of over 900 chemicals, ranging from naturally occurring substances to synthetic additives. If your product contains any of these chemicals above the "Safe Harbor" limits, you must label it.
Who Needs to Comply?
Generally, Prop 65 applies to your business if:
You have 10 or more employees.
You sell products in California (even through e-commerce or third-party distributors).
Your products contain listed chemicals above the No Significant Risk Level (NSRL) or Maximum Allowable Dose Level (MADL).
Critical Updates: The 2025 Warning Changes
The most urgent update for compliance teams involves the short-form warning labels.
Previously, businesses could use a generic "short-form" warning (e.g., WARNING: Cancer and Reproductive Harm) on small products without naming a specific chemical. However, amendments effective January 1, 2026, have tightened these rules.
Key 2025 Changes:
Chemical Specificity: The new short-form warning must now include the name of at least one listed chemical that prompted the warning. You can no longer remain vague.
Usage on All Sizes: The restriction that limited short-form warnings to "small packages" has been lifted, meaning you can use the short-form on any product size, provided it meets the new content requirements.
Signal Words: You can now use "CA WARNING" or "CALIFORNIA WARNING" in addition to just "WARNING."
Note: Companies generally have a grace period to transition, but proactive compliance is essential to avoid inventory bottlenecks.
The Cost of Non-Compliance: It’s Not Just the Fine
Failing to comply with Prop 65 is expensive. The statutory penalty can be up to $2,500 per violation per day. However, the real threat comes from private enforcers, often called "bounty hunters."
These private law firms and citizens can file lawsuits against businesses for alleged violations. Because they are entitled to a portion of the settlement and their attorney fees, there is a massive financial incentive to find unlabeled products.
Average Settlement Costs: Settlements often reach tens of thousands of dollars, not including your own legal defense fees.
Brand Damage: Public notices of violation can erode consumer trust.
Retailer Gatekeeping: Major retailers (like Amazon, Walmart, and Target) may delist your products if you cannot prove compliance or provide the correct warning data.
How GoCompliance Simplifies Prop 65 Management
Managing Prop 65 manually (tracking 900+ chemicals across thousands of supplier parts via email and spreadsheets) is a recipe for disaster.
GoCompliance transforms this chaotic process into a streamlined, automated workflow directly within your existing Oracle ecosystem.
1. Automated Supplier Data Collection
Stop chasing suppliers with manual emails. GoCompliance automates the outreach process, allowing suppliers to input full material declarations (FMDs) or simple compliance statements directly into the portal. Our system validates the data instantly against the current Prop 65 list.
2. Real-Time Risk Identification with AI
The Prop 65 list changes frequently. When OEHHA adds a new chemical (like the recent additions of certain PFAS or bisphenols), our Compliance Monitoring Agent automatically scans your Bills of Materials (BOMs). It flags exposed products immediately, so you don't have to manually cross-reference new chemicals against old parts.
3. Oracle-Native Integration
Because GoCompliance is built natively for Oracle Cloud PLM, you don’t have to deal with clunky third-party connectors. Your compliance data lives where your product data lives. This ensures that:
Engineering can see compliance status during the design phase.
Procurement is alerted to high-risk suppliers before orders are placed.
You have a "Single Source of Truth" for audits.
4. Effortless Reporting
Need to prove due diligence to a retailer or regulator? Generate comprehensive reports showing exactly which chemicals are in your products, their concentration levels, and your supplier declarations—all with a few clicks.
Next Steps: Protect Your Business Today
The regulatory landscape in California is shifting. Don’t wait for a Notice of Violation to update your compliance strategy.
Ready to automate your Prop 65 program? Book a Demo with GoCompliance today and see how our AI-driven, Oracle-native solution can turn regulatory risk into a competitive advantage.
Or, review out platform at your own pace via our free-to-access product demo.