In September 2025, 509 Proposition 65 Notices of Violation were issued in California. PFOA and PFOS were specifically cited in enforcement actions targeting waterproof cosmetics, coated fabrics, and packaging materials, demonstrating heightened Prop 65 enforcement activity against PFAS-containing consumer products. Products cited include outerwear, rain jackets, baby bibs, shower curtains, umbrellas, bags, cosmetics, and paper straws. This enforcement trend underscores the need for manufacturers to ensure compliance with Prop 65 warning requirements for products containing listed PFAS chemicals.
Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonate (PFOS) were listed effective November 10, 2017, as known to the State of California to cause reproductive toxicity (developmental endpoint) under the authoritative bodies mechanism (US EPA). Manufacturers, importers, and distributors of products containing PFOA or PFOS above significant exposure levels must provide Proposition 65 warnings. PFOA was subsequently listed for cancer (effective February 25, 2022) and PFOS was listed for cancer (effective December 24, 2021), expanding warning requirements for these PFAS chemicals.