This presentation was provided at the 2020 Regulatory Workshop. The presenters, Will Wagner and Jon Greenberg, presented on Prop 65 and Spices and Regulatory Policies for Heavy Metals in Spices - A New York Approach.

California Proposition 65 or “Prop 65”, calls for consumer product labeling or warnings in the workplace for substances determined to be carcinogens or reproductive toxins. The spice industry has been the target of increased enforcement activity under Prop 65, and private enforcers have issued dozens of notices of violation for alleged exposures to listed chemicals (namely heavy metals) in spices, as well as processed products that feature spices as prominent ingredients. The white paper has been updated to provide an overview of key aspects of Prop 65, including enforcement trends for heavy metals in spices, relevant safe harbor levels for heavy metals, methods to calculate exposures to listed chemicals from spices, and warning label requirements.