Prop 65 Roundup - January 2026

ICYMI: Introducing Prop 65 Unboxed: The AFS Video Series on the Latest Prop 65 News and Trends

Our new series “Prop 65 Unboxed” brings practical insights on Proposition 65 enforcement trends, legislative updates, and strategies to help businesses stay ahead. The first episode focuses on a critical issue: the growing risk of Prop 65 Notices of Violation for alleged BPS in receipt paper used in California stores. Consumer Products Co-Leader Lynn R. Fiorentino shares three smart ways companies can prepare and reduce exposure.
 
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OEHHA Notices

N-Methyl-N-Formylhydrazine Added to the Proposition 65 List for Cancer 

Effective December 8, 2025, OEHHA added N-methyl-N-formylhydrazine to the Proposition 65 list as a carcinogen. This listing was done via the “State’s Qualified Experts” mechanism, based on the Carcinogen Identification Committee’s (CIC) determination that this chemical was clearly shown to cause cancer. 
 
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BPS Added to the Proposition 65 List for Developmental Toxicity

Effective December 8, 2025, OEHHA has added the developmental toxicity endpoint to the reproductive toxicity listing of bisphenol S (BPS) under Proposition 65. This addition was done via the “State’s Qualified Experts” listing mechanism, based on the Developmental and Reproductive Toxicant Identification Committee’s determination that this chemical was clearly shown to cause developmental toxicity.
 
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Request for Relevant Information on the Carcinogenicity of Ethoprop

OEHHA is referring ethoprop to the CIC, the state’s qualified experts for carcinogenicity determinations under Proposition 65, for review for possible delisting. The publication of this notice marks the start of a 45-day data call-in period, ending on February 2.
 
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