SG 152/26
California is considering adding PFBA, PFDA, PFHxA and related salts to the Proposition 65 (Prop 65) list, potentially creating new warning obligations for businesses.
California Prop 65 is the ‘Safe Drinking Water and Toxic Enforcement Act of 1986’. It requires businesses to provide a clear and reasonable warning before knowingly and intentionally exposing anyone to a listed chemical. Unless exempt, businesses have 12 months to comply with this Prop 65 provision once a chemical is listed. Failure to provide a warning may not only result in lawsuits but also civil penalties of up to USD 2,500 per violation per day.
On October 30, 2026, the California Office of Environmental Health Hazard Assessment (OEHHA) opened a one-month consultation on proposals to add perfluorobutanoic acid (PFBA), perfluorodecanoic acid (PFDA), perfluorohexanoic acid (PFHxA) and related salts to the Prop 65 list of chemicals. These substances belong to the PFAS class, which includes chemicals used to impart resistance to oil, water and stains in a wide range of industrial and consumer applications.
What do the proposed listings cover?
OEHHA proposes listing PFBA, PFDA and PFHxA, together with related salts, under Prop 65 through the authoritative bodies listing mechanism. The proposed listings are summarized in Table 1.
| Item | PFAS | Proposed toxicity endpoint |
|---|---|---|
| 1 | PFBA and related salts | Reproductive toxicity (developmental, male reproductive and female reproductive endpoints) |
| 2 | PFDA and related salts | |
| 3 | PFHxA and related salts | Reproductive toxicity (developmental endpoint) |
Table 1. Proposed Prop 65 listings for three PFAS and related salts.
Who is impacted?
The proposals would affect stakeholders across the consumer products supply chain, including manufacturers, importers, retailers and other intermediaries operating in California.
When is the deadline for comment?
Comments will be accepted until November 30, 2026.
Companies doing business in California, USA, need to be aware of and comply with Proposition 65. We provide analytical testing and consultancy services to evaluate your products and guide you toward Prop 65 compliance. Contact us to learn more, or visit our website. In the end, it’s only trusted because it’s tested.
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