California Considers Listing p,p’-bisphenol Chemicals as Reproductive Toxicants Under Proposition 65

Published By DPRJ Universal | Published on Thursday, 6 November 2025

California's OEHHA is reviewing the class of p,p’-bisphenol chemicals, including BPA alternatives, for possible listing under Proposition 65 as reproductive toxicants. This could expand warning requirements to numerous consumer and industrial products, raising compliance challenges and potential litigation risks. Public comments are open until December 1, 2025, as the state seeks evidence on reproductive toxicity from these chemicals.

On October 21, 2025, California's Office of Environmental Health Hazard Assessment (OEHHA) announced the selection of the entire class of p,p’-bisphenol chemicals for review by the Developmental and Reproductive Toxicant Identification Committee (DARTIC) for potential listing under Proposition 65 as reproductive toxicants. This class includes not only well-known bisphenols like BPA and BPS (already listed) but also other structurally similar chemicals such as bisphenol AF, AP, B, and Z, which have been used as BPA and BPS replacements. The proposed listing could trigger new requirements for warning labels on many consumer and industrial products, affecting companies that have shifted to these alternatives. Proposition 65, enacted in 1986, mandates warnings for chemicals known to cause cancer or reproductive harm and allows private enforcement actions that have resulted in numerous current violations, particularly concerning BPS. OEHHA is soliciting public input on relevant scientific studies concerning the reproductive toxicity of these chemicals, with the comment period closing December 1, 2025. This broad potential listing reflects similar assessments by the European Chemicals Agency and poses complex compliance and litigation risks for manufacturers and retailers in California, especially given the risk of regrettable substitution. Companies are advised to proactively identify and manage p,p’-bisphenol exposures in their supply chains and consider submitting evidence to refine the scope of any listing.