Guidance on California Proposition 65 for herbal products

Guidance on California Proposition 65 for herbal products

Updated August 2018, this guidance covers heavy metals, naturally occurring substances and two processed botanicals

Published: Thursday, August 30, 2018

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AHPA updated this Proposition 65 guidance in August 2018 to inform the herbal products industry about legal liabilities related to naturally occurring substances in some natural products sold in the state of California.

Under Prop 65, consumer goods sold in the state generally must provide a "clear and reasonable warning" if chemicals listed by the state as "carcinogens" or "reproductive toxicants" are present above specified limits. California amended Prop 65 warning requirements in August 2016 and the changes are scheduled to be effective in August 2018. AHPA's Guidance on California Proposition 65 and Herbal Products provides detailed information about these changes and options for implementation.

Several chemical constituents that naturally occur in certain botanicals used in teas and dietary supplements are included on the Prop 65 warning list. Recently, two processed botanicals were also added to the list.

The document includes Prop 65 guidance on: 

  • Heavy metals 
  • Naturally occurring constituents pulegone and β-myrcene 
  • Goldenseal root powder 
  • Aloe vera, non-decolorized whole leaf extract

Over the last decades, numerous brand marketers, contract manufacturers, retailers and other companies that sell or manufacture herbal products have been the targets of Prop 65 complaints and the allegations can be costly.

"Like most companies that sell goods in California, companies that sell products with herbal ingredients must understand Proposition 65 and how it impacts their business," said AHPA President Michael McGuffin. "AHPA's guidance will help companies navigate this law to identify and mitigate legal liabilities."

AHPA Members Log In to download this guidance below.

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