ISSA Opposes California Prop 65 Proposed Limitations on Short-Form Warning

April 8, 2021

In formal comments filed with the State of California, ISSA strongly opposed a proposed rule that would significantly limit the “short-form” warning that has become popular in the cleaning industry since it became law just a few short years ago.

ISSA’s opposition was premised on the substantial and unreasonable adverse economic impact the proposed rule is expected to have on the hundreds of ISSA members who adopted the short-form warning after it became effective in 2018. These companies invested substantial resources in changing their labels to incorporate the short-form warning in good faith reliance on the rulemaking that adopted the short-form warning. The rule proposed by California, however, would require virtually all companies that use the short-form warning, to once again change their labels at great expense.

Moreover, the proposed rule would impose additional stress on the cleaning industry supply chain at a time during which it is already facing unprecedented challenges in its efforts to supply cleaning products and services to combat the COVID-19 pandemic.

While the proposed rule would place a tremendous economic burden on the cleaning industry, California has failed to demonstrate that it provides any health and safety benefit to those who procure and use products regulated under Prop 65.

ISSA therefore urged California to withdraw the proposed rule because it would create an unreasonable adverse economic impact and yet fail to achieve any measurable public health benefit.