Dennis Raglin Quoted in Chemical Watch: “Proposed Prop 65 Amendments Would Include QR Code Option for California Warnings”

Dennis Raglin was quoted in a Chemical Watch article titled “Proposed Prop 65 Amendments Would Include QR Code Option for California Warnings.” The article discusses potential amendments to California’s Proposition 65 — proposed by the state’s Office of Environmental Health Hazard Assessment (OEHHA) — that would update how chemical exposure warnings are communicated to customers.

Included in the proposal is an amendment that would expressly allow QR codes as a Prop 65 warning method. Raglin said some companies are already using these codes under existing Prop 65 regulations governing electronic warning methods and that the OEHHA likely contemplated those codes when drafting these provisions. However, he continued, the proposed amendment would require businesses to name a specific chemical alongside the code.

Raglin compared the QR proposal to the OEHHA’s 2024 overhaul of its Prop 65 short-form warning, which modified the state’s regulations to require businesses to identify at least one specific chemical beginning in 2028. He said both changes reflect a broader effort by the agency to move away from warning formats that do not identify chemicals by name. “This proposed change to the QR code regulation simply continues OEHHA’s quest to ensure a consumer sees immediately there is a chemical in the product,” Raglin said. “It fits OEHHA’s pattern of neutering any warning method that does not include the name of chemicals.”

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