What Are the Prop 65 Violation Numbers for 2025? (And Why It Matters to Your Business)

Introduction: Increasing Prop 65 Enforcement Activity

California Proposition 65 enforcement continues to intensify, and 2025 is emerging as one of the most active years on record. Businesses selling products into California must understand current enforcement trends to properly assess risk and maintain compliance.

This article reviews current 2025 Prop 65 violation data, explains what those numbers represent, and outlines how businesses can reduce exposure to enforcement actions.

Prop 65 Violations in 2025

Enforcement activity is typically measured using 60-Day Notices of Violation (NOVs), which serve as the primary indicator of Prop 65 violations.

Current 2025 Estimate:

• More than 5,000 Notices of Violation (NOVs)

This estimate is based on partial-year reporting and enforcement trends that already exceed previous years.

Reference Sources

• OEHHA 60-Day Notice Database
• National Law Review – 2025 Prop 65 Enforcement Trends

What Counts as a Prop 65 Violation?

Most reported violations refer to 60-Day Notices of Violation, which are legal notices issued prior to litigation.

• Filed by private enforcers or law firms
• Allege exposure to listed chemicals without proper warning
• Publicly recorded in the OEHHA system

These notices represent the primary enforcement metric used to track Prop 65 activity.

Settlements Compared to Notices

Only a portion of notices result in settlements.

Example Benchmark:

• Approximately 797 settlements recorded in 2023

Key Insight:

• Notices of Violation: Thousands per year
• Settlements: Hundreds per year

2025 Enforcement Trend Analysis

Prop 65 enforcement is not only high—it is increasing in frequency and consistency.

• Monthly enforcement remains elevated
• More than 600 notices issued in a single month in some periods
• Enforcement activity is sustained across industries

These trends indicate continuous enforcement pressure rather than isolated spikes.

Top Chemicals Driving 2025 Violations

A majority of enforcement actions are associated with a limited group of chemicals:

• Lead (Pb) – food products, supplements, ceramics
• Cadmium – cocoa products, metals, jewelry
• Phthalates (DEHP, DBP) – plastics and packaging
• PFAS – textiles and food contact materials
• Acrylamide – coffee and processed foods

These chemicals are commonly cited due to their widespread presence in consumer products.

Why 2025 Enforcement Matters for Your Business

The volume of notices indicates that thousands of businesses are being targeted annually.

Even if your product:

• Includes a warning label
• Has been tested periodically
• Is manufactured by a third-party supplier

Risk remains if your compliance program lacks:

• Ongoing monitoring
• Structured documentation
• Defensible compliance systems

The Real Risk: Notices Precede Litigation

Prop 65 enforcement risk begins with the issuance of a 60-day notice, not the filing of a lawsuit.

This often results in:

• Immediate settlement pressure
• Legal and consulting costs
• Marketplace disruptions (including Amazon and Walmart)
• Reputational impact

How to Reduce Prop 65 Risk in 2025

Businesses should implement structured compliance systems that include:

• Product-level chemical risk assessments
• Supplier disclosure programs
• ISO 17025 laboratory testing verification
• Safe harbor evaluations (NSRL and MADL)
• Warning justification documentation
• Batch and lot-level monitoring systems

How Prop65Compliance.com Supports Compliance

Prop65Compliance.com provides compliance support focused on monitoring, documentation, and risk reduction.

• Identification of exposure risks
• Testing coordination and verification
• Compliance documentation systems
• Ongoing monitoring and reporting

The objective is to help businesses maintain defensible and scalable compliance systems.

Final Takeaway

Prop 65 enforcement activity in 2025 has exceeded 5,000 Notices of Violation, making it one of the most active enforcement years to date.

The data underscores a critical conclusion: enforcement is ongoing, widespread, and increasing.

Next Steps

Businesses that proactively implement testing, documentation, and monitoring systems are better positioned to reduce enforcement risk and maintain compliance.

A structured compliance approach remains the most effective strategy for managing Prop 65 obligations.