Proposition 65
August 18, 2026 | Written by GreenSoft Technology, Inc.
OEHHA Releases Proposition 65 Omnibus 2026 Pre‑Rulemaking Draft
OEHHA Accepting Public Comments on Potential Amendments to Prop 65
The California Office of Environmental Health Hazard Assessment (OEHHA) has released its Proposition 65 Omnibus 2026 Pre‑Rulemaking draft, outlining several potential amendments the Proposition 65 regulation that may affect how electronics manufacturers communicate chemical exposure risks to consumers.
OEHHA is accepting public comments on the protentional amendments through September 8, 2026, following a public workshop held on July 30, 2026. Comments can be submitted here.
Key Proposed Changes Affecting Electronics Manufacturers
This article highlights the topics from the Omnibus package most relevant to companies producing finished electronics, sub‑assemblies, cables, power supplies, connectors, industrial controls, and other electrical/electronic components.
New Tailored Warning Option for Off‑Road Vehicle & Equipment Parts
Electronics manufacturers supplying components for off‑road vehicles, industrial machinery, construction equipment, mining equipment, agricultural equipment, and forestry equipment may soon have access to a new tailored warning pathway.
OEHHA proposes adding Sections 25607.54 and 25607.55, which would allow manufacturers to provide Proposition 65 warnings during:
- Purchase
- Handling
- Installation
This is particularly relevant for electronics used in:
- Control systems
- Sensors
- Power modules
- Wiring harnesses
- Embedded electronics in heavy machinery
Why this matters for electronics suppliers
Many electronics used in off‑road and industrial equipment contain chemicals listed under Proposition 65, such as lead, phthalates, flame retardants, and PAHs. The new tailored warning option may simplify compliance by allowing warnings to be delivered through:
- Full‑length warnings
- Short‑form warnings
- Retail signage (minimum 5×5 inches, 20‑point type)
- Online or catalog warnings for e‑commerce sales
This flexibility may reduce packaging constraints and streamline communication across complex supply chains.
Alignment of Short‑Form Warning Chemical Descriptors
OEHHA proposes a technical correction to align chemical descriptor language between short‑form and full‑length warnings. Affected sections: 25603(b) and 25607.2(b).
Impact on electronics manufacturers
Electronics often require short‑form warnings due to limited packaging space. Aligning descriptor language will:
- Reduce inconsistencies across product lines
- Simplify packaging updates
- Improve clarity for distributors and retailers
This change is minor but meaningful for companies managing large SKU counts.
Clarification on “Naturally Occurring” Chemicals
OEHHA proposes refining Section 25501(a)(3) to clarify when a chemical is considered “naturally occurring.”
Relevance to electronics
While most chemicals in electronics are intentionally added, this clarification may affect:
- Raw materials (metals, minerals, ceramics)
- Components sourced from natural materials
- Suppliers claiming exemptions for trace contaminants
Electronics manufacturers should review supplier declarations carefully to ensure “naturally occurring” claims are valid under the updated definition.
Updated Requirements for Internet Purchase Warnings
OEHHA proposes updates to Sections 25600.2(b) and 25602(b) to clarify when warnings must be displayed for online purchases.
Impact on electronics manufacturers and distributors
This is highly relevant for companies selling through:
- Direct e‑commerce
- Online distributors
- Marketplaces (Amazon, Digi‑Key, Mouser, etc.)
The proposed updates aim to reduce ambiguity around:
- Placement of warnings on product pages
- Visibility requirements before checkout
- How warnings must appear in mobile vs. desktop formats
Electronics companies with large online catalogs should prepare for potential adjustments to product listings.
Addition of QR Codes as an Approved Warning Method
OEHHA proposes allowing QR codes as a compliant method for delivering Proposition 65 warnings. Affected sections: 25601(c) and 25602(a)(2).
Why this matters for electronics
Electronics packaging often has limited space due to small form factors, technical labeling requirements, and certification marks (CE, UL, FCC, RoHS, etc.)
QR codes may provide a practical solution by linking consumers to:
- Full warning text
- Chemical information
- Exposure details
- Multi‑language content
This modernization could significantly reduce packaging redesign costs.
Impact on Electronics Manufacturers Selling Into California
Proposition 65 applies to any company selling products into California, regardless of where the manufacturer is located. This includes:
- U.S. electronics manufacturers
- European component suppliers
- Asian OEMs and ODMs
- Distributors and importers
- Online retailers serving California customers
If your products contain listed chemicals such as lead, nickel, phthalates, cadmium, or certain flame retardants, these proposed updates may affect your warning strategy.
How GreenSoft Supports Proposition 65 Compliance
GreenSoft Technology provides comprehensive Proposition 65 Data Services designed specifically for electronics manufacturers and component suppliers.
Our services include:
- Supplier data collection and validation
- Identification of Proposition 65 listed chemicals in components
- Exposure pathway analysis
- Determination of warning applicability
- Automated warning management through GreenData Manager (GDM)
- Monitoring of regulatory updates, including Omnibus 2026 changes
- Audit‑ready documentation for customers and regulators
With thousands of electronics manufacturers relying on GreenSoft’s data services and software, we help companies reduce compliance risk, streamline supplier communication, and maintain accurate, up‑to‑date chemical information.
Stay Ahead of Proposition 65 Changes
The proposed updates may require adjustments to your warning strategy, packaging, online listings, and supplier communication workflows. GreenSoft can help you evaluate the impact and implement compliant, cost‑effective solutions.
Contact us to learn how our Prop 65 Data Services can support your compliance program.
