10A: Supplier Ingredient Disclosure Challenges and Prop 65

Grand Hyatt Denver 

Room: Mt. Sopris A 

CM Credit Hours: 0.5 

California's Proposition 65 presents significant and often confusing compliance hurdles for consumer product manufacturers. Even manufacturers that work closely with their suppliers and monitor their ingredient portfolio can be taken by surprise with a 60-day notice of violation. Manufacturers must understand their raw materials and the information they need to verify whether their products are compliant or require warning labels. Often, manufacturers must investigate beyond the ingredients added intentionally to their products, as undisclosed residuals, additives, and impurities may also trigger noncompliance notices. Proactively engaging with suppliers, maintaining an open dialogue, and asking the right questions is critical to manufacturers' success. It is also important for manufacturers to understand that, while the presence of a chemical can trigger a 60-day notice, exposure to the chemical is what matters under Prop 65.

During this session, the speaker will present case studies on Prop 65 violations in food and other consumer products. She will also provide possible strategies and recommendations for supplier communication, oversight, and product testing to help participants understand compliance requirements.

Upon completion, the participant will be able to…

• Explain the nuances of California Prop 65 relating to chemical ingredient disclosures and supplier communications.
• Adopt possible strategies and recommendations from case studies involving food and other consumer products, including analytical testing approaches.
 

Value Chain/Supply Chain Communications & Challenges

Domain II: Communication

Domain IV: Regulatory Compliance

Intermediate

Q&A