Upcoming changes

2 rules in Proposition 65 list of chemicals known to the State to cause cancer or reproductive toxicity (27 CCR 27001), OEHHA list, for products sold, from 8 Dec 2026. Applies when: Seller has 10 or more employees; Your business has 10 or more employees and the product knowingly and intentionally exposes someone in California to this chemical.

• Bisphenol S (BPS) (CAS 80-09-1)

  Listed 2025-12-08 (developmental). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

• N-Methyl-N-Formylhydrazine (CAS 758-17-8)

  Listed 2025-12-08 (cancer). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

Applies to products sold on or after 1 Jan 2027. Applies when: It contains intentionally added PFAS.

The information must be submitted on or before January 1, 2027. The Department may extend the deadline or waive the duty where equivalent information is publicly available.

Applies to products sold on or after 1 Jan 2027. Applies when: Contains a battery; It contains or is packaged with a covered battery (a portable battery or, beginning January 1, 2029, a medium format battery, RCW 70A.555.010(1)(a), (5)(a)); a battery that is not intended or designed to be easily removable from the battery-containing product is not a covered battery (70A.555.010(5)(b)(v)), and you are its producer (70A.555.010(14)).

Stated: “Beginning January 1, 2027” (70A.555.020).

Applies to products manufactured on or after 31 Jan 2027. Applies when: Your role: Manufacturer or Importer; You manufactured (including imported) a PFAS, or an article containing one, for commercial purposes at any time from January 1, 2011 through December 31, 2022.

Stated in §705.20(a)-(b): “the submission period shall begin January 31, 2027, or 60 days following the date provided in paragraph (c) of this section, whichever is earlier”. Paragraph (c): “EPA intends to publish a document in the Federal Register announcing the submission period date and revising or removing this paragraph (c).” The period had not begun on the date this row was made (2026-10-26); the date is the latest start the text allows.

11 rules in Regulation (EU) 2023/1542 concerning batteries and waste batteries, for products placed on the market, from 18 Feb 2027. Conditions differ by rule; see below.

• Art. 11 removable-replaceable-lmt

  Applies when: Your role: Manufacturer or Importer; Battery is incorporated in an appliance or vehicle · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

• Art. 11 software-no-impediment

  Applies when: Your role: Manufacturer or Importer · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

  Applies when: Your role: Manufacturer or Importer; Battery is incorporated in an appliance or vehicle · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

• Art. 11 spare-part-availability

  Applies when: Contains a battery; Battery category: Portable battery or LMT battery (e-bike, e-scooter); Your role: Manufacturer or Importer · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

• Art. 77(10)

  Applies when: Your role: Manufacturer or Importer

  Applies when: Your role: Manufacturer or Importer; Rated energy more than 2000 Wh

• Art. 77(4)

  Applies when: Your role: Manufacturer or Importer

  Applies when: Your role: Manufacturer or Importer; Rated energy more than 2000 Wh

• Battery passport (Annex XIII), accessible by QR code

  Applies when: Your role: Manufacturer or Importer

  Applies when: Your role: Manufacturer or Importer; Rated energy more than 2000 Wh

• QR code (Annex VI Part C)

  Applies when: Your role: Manufacturer or Importer or Distributor

Applies to products sold on or after 1 Mar 2027. Applies when: Contains a battery; It contains an embedded battery (a portable battery or medium format battery that is contained within a battery-containing product and that is not intended or designed to be easily removable from the product, 38 M.R.S. 1617(1)(M)), and you are the producer participating in a battery stewardship program (1617(2)(B)).

Stated: “Beginning March 1, 2027” (1617(2)(B)); “This paragraph is repealed January 1, 2030.” From then embedded batteries are covered batteries (1617(1)(I)(1)).

Applies to products sold on or after 1 Jul 2027. Applies when: Contains a battery; It contains or is packaged with a covered battery (a portable battery or, beginning January 1, 2029, a medium format battery, RCW 70A.555.010(1)(a), (5)(a)); a battery that is not intended or designed to be easily removable from the battery-containing product is not a covered battery (70A.555.010(5)(b)(v)), and you sell or offer it in or into Washington (a retailer, 70A.555.010(19)).

Stated: “Beginning July 1, 2027, for portable batteries, and July 1, 2029, for medium format batteries” (70A.555.030(1)).

4 rules in Proposition 65 list of chemicals known to the State to cause cancer or reproductive toxicity (27 CCR 27001), OEHHA list, for products sold, from 17 Jul 2027. Applies when: Seller has 10 or more employees; Your business has 10 or more employees and the product knowingly and intentionally exposes someone in California to this chemical.

• Hydrochlorothiazide

  Listed 2026-07-17 (cancer). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

• Tacrolimus (CAS 104987-11-3)

  Listed 2026-07-17 (cancer). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

• Voriconazole

  Listed 2026-07-17 (cancer). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

• Welding Fumes

  Listed 2026-07-17 (cancer). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

12 rules in Regulation (EU) 2023/1542 concerning batteries and waste batteries, for products placed on the market, from 18 Aug 2027. Conditions differ by rule; see below.

• Art. 49(2)

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Art. 50(3)

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence annual-public-report

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence authority-disclosure

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence downstream-disclosure

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence management-system

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence policy

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence records

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence risk-management

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence third-party-verification

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Carbon footprint label-class (Art. 7)

  Applies when: Rated energy more than 2000 Wh; Rechargeable; Your role: Manufacturer or Importer or Distributor · Art. 7(2)(b) rechargeable industrial batteries over 2 kWh. Batteries with exclusively external storage have a later date (2032-02-18, Art. 7(2)(d)) in the same paragraph; no product fact separates them. The text adds 'or ... months after the date of entry into force of the delegated or implementing act, whichever is the latest'; the published text gives no entry-into-force date, so the stated calendar date is used. The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

• Minimum electrochemical performance and durability values (Annex IV Part A)

  Applies when: Rated energy more than 2000 Wh; Rechargeable; Your role: Manufacturer or Importer or Distributor · From 18 August 2027 or 18 months after the date of entry into force of the delegated act, whichever is the latest (Art. 10(2)). The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

Applies to products placed on the market on or after 31 Dec 2027. Applies when: Your role: Manufacturer or Importer or Distributor.

Target date 2027-12-31 as stated; Chapter VIII applies from 18 August 2025 (Art. 96(2)(c)).

8 rules in Proposition 65 clear and reasonable warning regulations (27 CCR Article 6, OEHHA consolidation April 2025), for products manufactured, from 1 Jan 2028. Applies when: Your business has 10 or more employees and the product knowingly and intentionally exposes someone in California to a listed chemical.

• Consumer products that expose a person to a chemical on the Proposition 65 list

  Short-form text required for products manufactured on or after 2028-01-01; available as an option earlier (§25603(b)). Products manufactured and labeled before 2028-01-01 may keep the §25603(c) legacy short form.

Applies to products sold on or after 1 Jan 2028. Applies when: It contains intentionally added PFAS.

Applies to products placed on the market on or after 18 Feb 2028. Applies when: Your role: Manufacturer or Importer or Distributor.

Art. 7(3)(a) electric vehicle batteries. The text adds 'or ... months after the date of entry into force of the delegated or implementing act, whichever is the latest'; the published text gives no entry-into-force date, so the stated calendar date is used. The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

5 rules in Regulation (EU) 2023/1542 concerning batteries and waste batteries, for products placed on the market, from 18 Aug 2028. Conditions differ by rule; see below.

• Carbon footprint declaration (Art. 7)

  Applies when: Your role: Manufacturer or Importer or Distributor · Art. 7(1)(c) LMT batteries. The text adds 'or ... months after the date of entry into force of the delegated or implementing act, whichever is the latest'; the published text gives no entry-into-force date, so the stated calendar date is used. The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

• Minimum electrochemical performance and durability values (Annex IV Part A)

  Applies when: Your role: Manufacturer or Importer or Distributor · From 18 August 2028 or 18 months after the date of entry into force of the delegated act, whichever is the latest (Art. 10(3)). The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

• Minimum electrochemical performance and durability values of portable batteries of general use

  Applies when: Contains a button or coin cell: no; Your role: Manufacturer or Importer or Distributor · From 18 August 2028 or 24 months after the date of entry into force of the delegated act, whichever is the latest (Art. 9(1)). The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

• Recycled content documentation (Art. 8(1))

  Applies when: Battery chemistry: Lithium-ion or Lithium (non-rechargeable) or Nickel-metal hydride or Nickel-cadmium or Lead-acid; Rated energy more than 2000 Wh; Your role: Manufacturer or Importer or Distributor · Industrial batteries over 2 kWh (not exclusively external storage), electric vehicle batteries and SLI batteries that contain cobalt, lead, lithium or nickel in active materials; the stated date is 2028-08-18 or 24 months after the delegated act, whichever is the latest. The capacity bound for industrial batteries and the active-material content are not product facts here, so the rule is scoped on the whole categories. The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

  Applies when: Battery chemistry: Lithium-ion or Lithium (non-rechargeable) or Nickel-metal hydride or Nickel-cadmium or Lead-acid; Your role: Manufacturer or Importer or Distributor · Industrial batteries over 2 kWh (not exclusively external storage), electric vehicle batteries and SLI batteries that contain cobalt, lead, lithium or nickel in active materials; the stated date is 2028-08-18 or 24 months after the delegated act, whichever is the latest. The capacity bound for industrial batteries and the active-material content are not product facts here, so the rule is scoped on the whole categories. The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.