On April 5, 2022, the California Office of Environmental Health Hazard Assessment (OEHHA) announced a second 15-Day Modification to Proposed Amendments to Article 6 – Clear and Reasonable Warnings for Consumer Product Exposures.

The latest consultation stems from the Notice of Proposed Rulemaking (NPR) of January 2021. After an extended public comment period, to March 2021, followed by the first 15-day modification of December 2021, the OEHHA proposed to further amend its requirements for consumer product exposure warnings. It: 

• Allows the use of short-form warnings on product labels of any size, regardless of package size and shape, by removing the limitations for the use of these product labels (Section 25602(a)(4))

• Removes the provision where the font type size must be the same as the largest type size providing consumer information, but retains the requirement of a minimum of 6-point type size when using short-form warnings (Section 25602(a)(4)) – the entire warning must be clearly visible, easily legible, understandable and comply with Section 25601(c)

• Modifies the language ‘exposes you to’ to ‘can expose you to’ (Subsections 25603(b) and 25607.2(b))

• Changes the regulation’s operative date from ‘one year’ to ‘two years’ after the effective date of the amendments to allow businesses to implement changes to the short form

Examples of short form warning:

BACL Service:

Bay Area Compliance Labs Corp.( BACL for short), with its headquarter in Silicon Valley, it is a professional and international third-party testing and certification body. Currently we have physical and chemical testing labs in the United States, Shenzhen, Dongguan, Xiamen and other places, and we have accredited the certifications by UKAS (Lab No.: 7827), CNAS (Registration No.: L2408, L6290, L9963, IB0343), CPSC(Lab ID:1112, 1415, 1647), CMA (No.: 2016192126Z, 2015192413Z) and other authorities. We offer a full range of testing service which cover footwear, toys, textile, clothing, leather, jewelry, groceries, food contact materials, cosmetics and electrical and electronic products, etc. We can help enterprises to complete the precise control of whole industry chain from raw materials to the finished products.