OEHHA Issues Information Letters Providing Prop 65 Guidance

In December 2025, the California Office of Environmental Health Hazard Assessment (OEHHA), the state agency responsible for implementing Proposition 65 (Prop 65), issued two "Information Letters" regarding Prop 65 compliance issues. Each is discussed below.

Warnings for Receipts/Labels Accompanying a Consumer Purchase

On December 8, 2025, OEHHA issued an Information Letter to provide guidance regarding Prop 65 warnings for Bisphenol S (BPS) in receipt paper and shipping labels. BPS was first listed under Prop 65 on December 29, 2023, for reproductive toxicity, based on the female reproductive endpoint. BPS was then listed for male reproductive toxicity on January 8, 2025, and again for developmental toxicity on December 8, 2025. Since its listing became effective, hundreds of businesses have received 60-day Notices of Violation (NOV) claiming that companies have not provided the "clear and reasonable" warnings for BPS based on its claimed presence in thermal