California Proposes Proposition 65 Omnibus Warning Updates

The California Office of Environmental Health Hazard Assessment (OEHHA) is considering a package of potential amendments to the Proposition 65 regulations. The Proposition 65 Omnibus 2026 package is currently at the pre-rulemaking stage and does not yet create new legal obligations.

The proposals concern several technical and warning-related issues. They could affect how businesses assess warning requirements, determine whether a warning is needed and provide warnings to consumers.

New option for off-road parts

One proposed change would create a tailored warning option for certain parts used in off-road vehicles and off-road equipment. The proposal is intended to provide additional flexibility for manufacturers and sellers of parts for construction, mining, agricultural, forestry and other non-road equipment.

Under the draft approach, a business could use a full-length warning, an applicable short-form warning or a tailored warning for exposures that may occur during the purchase, handling or installation of an off-road vehicle or equipment part.

The proposed tailored warning refers to potential exposure to chemicals such as phthalates and lead. It would also include practical exposure-reduction information, including servicing equipment in a well-ventilated area, wearing gloves and washing hands.

Technical warning-language change

OEHHA also proposes a technical correction to align the chemical-descriptor language used in short-form warnings with the wording used in full-length warnings.

The change would clarify the use of the phrase “chemicals including” when identifying one or more listed chemicals. It is intended to improve consistency between the different Proposition 65 warning formats.

Status and next steps

The Omnibus 2026 package remains a draft proposal. OEHHA held a public workshop on 30 July 2026, and the public-comment period ran from 22 July to 8 September 2026.

OEHHA will now review the comments received before deciding whether and how to proceed with a formal rulemaking proposal. Any final amendments would need to go through the formal California rulemaking process before becoming effective.

What this means for companies

No immediate action is required solely because of the Omnibus 2026 pre-rulemaking package. However, manufacturers, distributors and retailers that provide Proposition 65 warnings should monitor the next steps closely.

The proposed tailored warning may be particularly relevant to companies supplying electronics, components or replacement parts for off-road vehicles, construction equipment, mining equipment, agricultural equipment and forestry equipment.

Companies should review their existing Proposition 65 warning processes and product information for potentially affected product categories. They should also monitor any formal OEHHA rulemaking notice for final wording, transition periods and effective dates.

Source: California Office of Environmental Health Hazard Assessment, Proposition 65: Omnibus 2026 Pre-Rulemaking ; and Draft regulatory text for Omnibus 2026 .