What’s New This Month
July 2025 Prop 65 enforcement continued its upward trend, with over 600 notices issued. Bisphenol S (BPS) remained the most frequently cited chemical, while PFAS, cadmium, and phthalates also saw active enforcement across food, supplements, and consumer goods.
California Proposition 65 Enforcement: July 2025 Update
In July 2025, California saw 624 Notices of Violation (NOVs) under Proposition 65. This month’s data shows heightened activity targeting packaging, supplements, food, and consumer goods.
Below, we highlight the top chemicals, companies, and noticing parties driving this wave of enforcement.
July 1–31, 2025 Notice of Violation Summary
| Number of Violations | Listed Chemicals | Types of Products Targeted |
| 252 | Bisphenol S (BPS) | Thermal receipts, packaging, food containers |
| 179 | Lead | Supplements, powders, cookware |
| 42 | Lead and lead compounds | Seafood, ceramics, paints |
| 37 | Di(2-ethylhexyl)phthalate (DEHP) | Vinyl goods, bags, accessories |
| 16 | Alcoholic beverages (ethanol) | Beer, wine, spirits |
Enforcement Trends
BPS Dominates Notices – With 252 notices, BPS continues to be the most common target, especially in receipts and packaging.
Heavy Metals in Food and Supplements – Lead remained a recurring target in supplements and powders. See our Food Recall Tracker for the latest enforcement and recall activity.
Phthalates in Accessories – DEHP citations focused on vinyl-based consumer products such as bags and cases.
PFAS in Wellness Products – PFOA and PFOS enforcement continued, reflecting increased attention to persistent chemicals.
Product Categories Most Frequently Targeted
– Food & Beverage: Supplements, baking mixes, seafood, alcoholic beverages
– Cosmetics & Wellness: Lotions, bath bombs, CBD oils, sprays
– Household & Retail: Thermal receipts, packaging, vinyl goods
– Consumer Goods: Cookware, ceramic mugs, accessories
Top Chemicals, Companies, and Noticing Parties
Top Chemicals Cited
Top Companies Cited
| Company | Notices Received |
| Amazon.com, Inc. | 78 |
| The TJX Companies, Inc. | 31 |
| Ross Stores, Inc. | 16 |
| Walmart, Inc. | 12 |
| BPS Direct | 11 |
| Burlington Coat Factory of Texas | 10 |
| Whole Foods Market | 8 |
| Mrs. Gooch’s Natural Food Markets | 8 |
| VSI | 8 |
| GB MARKET LLC | 7 |
Top Noticing Parties
How Can My Company Avoid a Prop 65 Lawsuit?
- Test Imported Goods – Many July notices focused on imported supplements and cookware.
- Review Warning Placement – Ensure Prop 65 warnings are visible online and in-store.
- Train Sales & Marketing Teams – Staff should understand when and how warnings must be provided.
- Update Licensing and Distribution Contracts – Add Prop 65 indemnity clauses to shift liability appropriately.
- Engage Legal Counsel Quickly – Responding within the 60-day notice period is critical to reducing costs.
Frequently Asked Questions (FAQ)
Does Prop 65 apply to naturally occurring metals?
Yes. Even naturally occurring lead and cadmium in foods and botanicals can trigger violations.
Are retailers liable for online sales?
Yes. Online listings targeting California consumers must display Prop 65 warnings where required.
What should I do if my supplier is cited?
Retailers and distributors should review contracts to ensure suppliers indemnify them for Prop 65 liability.
Proposition 65 Q&A for Businesses and Manufacturers
Why is BPS enforcement increasing?
BPS is often used in place of BPA but lacks a safe harbor level, making it a frequent enforcement target, especially in receipts and labels.
What are safe harbor levels?
Safe harbor levels are thresholds below which warnings are not required. Many chemicals cited in July 2025 have no safe harbor levels, increasing risk.
Are PFAS enforcement actions here to stay?
Yes. PFAS chemicals like PFOA and PFOS are high-priority targets for regulators and plaintiffs due to health risks and persistence.
What industries are most exposed?
Food, supplements, packaging, and retail remain the most frequently cited categories in July 2025.
Want to Protect Your Brand from a Prop 65 Lawsuit?
To schedule a compliance audit or speak with a regulatory attorney, contact us today. Juris Law Group, recently recognized in Chambers’ USA Spotlight Rankings, is proud to be trusted by businesses nationwide for regulatory compliance and defense.
