Global Automakers

Comments on California Draft Proposition 65 Warning Requirements Proposal

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June 13, 2014

The Association of Global Automakers, Inc. submitted comments to the California Office of Environmental Health Hazard Assessment (OEHHA) on the draft proposed changes to the Proposition 65 (Prop 65) Warning Requirements. These comments were submitted jointly with the Alliance of Automobile Manufacturers, and the two Associations request that OEHHA reevaluate its draft changes, including:

  • Maintaining the current label wording because it more accurately characterizes (and will not mislead the consumer about) the potential exposure to the chemical;
  • Foregoing inclusion of the GHS pictogram on the warning requirements and instead continue to use “WARNING” to inform the consumer;
  • Considering a streamlined and harmonized approach to reduce the number of labels;
  • Providing three years lead time to implement any new warning requirement provision;
  • Providing additional time for any reporting requirements, with an option for additional flexibility in timing if needed;
  • Providing an explicit exemption from the warning requirements for replacement parts used to repair vehicles as produced;
  • Not requiring manufacturers to provide exposure information; and
  • Not requiring specific labels for complex durable goods and clarifying that a single, general notification, such as a warning in the owner’s manual, continues to comply with the Prop 65 warning requirements.
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