Cheryl S. Chang and Brittany Wei ●
The California Office of Environmental Health Hazard Assessment (“OEHHA”) is in the early stages of what it is calling the “Omnibus 2026” package of amendments to the Proposition 65 regulations—a set of eight proposed changes covering among other things, tailored warnings for machinery parts, alignment of the short-form warning, the naturally occurring exemption for chemicals in food, internet purchase warnings, retailer responsibility, and the potential addition of quick response (“QR”) codes as a warning method. The full draft regulatory text is available here: Topics of Proposed Regulatory Changes in Omnibus 2026.
Key Dates
OEHHA held its pre-regulatory workshop on the draft language on July 30, 2026. The written public comment period is open through September 8, 2026. No formal rulemaking hearing has been noticed yet, as OEHHA has stated that a formal rulemaking will be published sometime in the future, at which point a separate notice, public comment period, and response-to-comments process will begin. In the meantime, the next industry-wide forum on Proposition 65 developments is the Proposition 65 Clearinghouse’s Annual Conference on August 31, 2026, in San Francisco, a conference at which OEHHA is a supporting sponsor and typically participates in panel discussions.
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