Prop 65 checklist, row by row

Every row of a product's Prop 65 checklist, in the order the checklist shows them, with the regulation's full wording, who does the work, when it applies and each way to record it. The checklist itself keeps only the row's name, its citation and the buttons to record it.

INFO: This row records how the Proposition 65 warning for this product is handled: a warning on the label, written notice to the retailer, or your recorded determination that no warning is needed. Written notice to the retailer has to be renewed every year and acknowledged in writing.

Consumer product exposure warning (27 CCR 25600.2(b), for each product). You may either put the warning on the product label, or send written notice to the retailer instead. Note also that a further notice is due within 90 days whenever a different or additional chemical or endpoint appears in the warning (§25600.2(c)(3)). If you have determined that this product does not need a warning, record that determination and your reason here instead.

When it does not apply (Cal. Health & Safety Code §25249.6) — once you record that, the row says: “You have recorded that this product is not sold in California, and Proposition 65 is a California statute. Add California to where this product is sold if that changes.”

Ways to meet it (any one):

• The warning is on the label — Confirm the Prop 65 warning appears on the product label or labeling.
• Written notice to the retailer (§25600.2(b)) — Confirm you sent written notice to the retailer's authorized agent, including the product identification and all warning materials.
  • Also record: The notice is renewed every year the product is sold in California (27 CCR 25600.2(b)(4))
  • Also record: You received written or electronic confirmation of receipt (27 CCR 25600.2(c)(1))
• No warning needed — your recorded determination — Record your determination that this product does not need a Proposition 65 warning, and your reason. Aleph does not check the determination — the reason you write is your record of it. Your note is the record, so it is required.

Source: 27 CCR 25600.2(b) — Register 2020, No. 1 (amendment filed 12-31-2019, operative 4-1-2020); Barclays Official CCR current through Register 2026, No. 32 (8/7/26). Read 2026-08-18.

Not required, but worth holding

• Lab Report — Establishes whether an exposure requiring a warning exists at all.
• Material Safety Data Sheet (MSDS/SDS) — Identifies listed chemicals present in the product.

INFO: This lists what the checklist records. It is not legal advice, and a row recorded in Aleph is not a finding that the product complies.