Global Automakers

Joint Comments on California's Proposed Prop 65 Warning Labels

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January 25, 2016

On January 25th, Global Automakers, Auto Alliance, and Motor Equipment Manufacturers Association (MEMA) submitted joint comments to California Office of Environmental Health Hazard Assessment (OEHHA) on the proposed Proposition 65 (Prop 65) Clear and Reasonable Warning Labels regulation. The comments requested OEHHA to address the following issues:

  • Provide more flexibility for label transmission methods
  • Clarify label formatting
  • Adjust label content
  • Amend definitions to account for various vehicle types
  • Make special allowances for aftermarket, replacement, and service parts or include them in the safe harbor warning
  • Clarify what is meant by “one or more chemical” in the generally-applicable warnings
  • Either exempt replacement parts or include them in the Safe Harbor Label
  • Consider the practical implications of excluding a de minimis exemption
  • Use the phrase “end users” instead of “purchasers”
  • Clarify how specific sections relate to the general section to ensure safe harbor protections
  • Avoid inadvertently requiring exposure assessments
  • Provide a three-year transition period

Details can be found in the full text of the attached comments. 

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