California Proposition 65: The Complete Compliance Guide for Car Dealerships and Auto Shops

California Proposition 65: The Complete Compliance Guide for Car Dealerships and Auto Shops

If you live in California, you're no stranger to the infamous Prop 65 warning signs. They're at Starbucks. They're at Home Depot. They pop up in online checkouts, at the zoo, on parking garage walls... everywhere you turn! At some point, most Californians have chuckled at one, wondered what it actually means, or simply walked past without a second thought. 

But if your dealership or auto shop operates in California, or sells vehicles to California customers, Proposition 65 compliance is not optional. This guide breaks down exactly what you need to know, what's required on every vehicle, and how to stay protected from fines that can reach $2,500 per violation per day.

What Is California Proposition 65?

California Proposition 65: officially the Safe Drinking Water and Toxic Enforcement Act of 1986 (more popularly called ‘Prop 65’) - is a state law that requires businesses to warn consumers before exposing them to chemicals known to cause cancer, birth defects, or other reproductive harm. Voters passed it as a ballot initiative and grown substantially since.

Today, the Proposition 65 list includes approximately 900+ chemicals, updated annually by the California Office of Environmental Health Hazard Assessment (OEHHA). The list includes naturally occurring and synthetic substances found in many, everyday products - including motor vehicles, parts, lubricants, coatings, and shop chemicals.

Any business with 10 or more employees that does business in California must comply. This includes:

  • New car dealerships
  • Used car dealers
  • Independent auto lots
  • Vehicle wholesalers and auctions
  • Rental car companies
  • Auto repair and body shops
  • Parts retailers and distributors
  • Out-of-state companies shipping products into California
  • If you sell a vehicle in California, or ship parts to a California customer,  Prop 65 applies to you.

Why Prop 65 Matters So Much for the Auto Industry

Vehicles are one of the most Prop 65-relevant consumer products in existence. Passenger cars, trucks, SUVs, motorcycles, and off-highway vehicles expose occupants, operators, and service technicians to a range of listed chemicals through:

  • Engine exhaust (carbon monoxide, benzene, toluene)
  • Fuel and oils (benzene, ethylbenzene)
  • Vehicle interiors (phthalates in plastics, flooring, and cable coverings)
  • Batteries (lead in lead-acid batteries)
  • Brake dust (asbestos in older vehicles; other listed substances in newer ones)
  • Motor vehicle parts handled during service and repair

Because exposure occurs both during vehicle use and during servicing, both dealerships and auto service shops have specific, distinct obligations under the law.

Proposition 65 Requirements for Car Dealerships

Vehicle Window Stickers: The Core Requirement

California requires dealers to affix an OEHHA-approved Prop 65 warning sticker to every vehicle on the lot: new, used, and loaner vehicles alike. This applies unless the manufacturer has formally assumed that responsibility by written contract.

Where the sticker goes: The warning must be affixed to the inside of the driver's side window, facing outward so it is clearly readable from outside the vehicle. If a vehicle has no driver's side window, the warning may be placed on the rearview mirror or another prominent location.

What the sticker must include:

  • The word WARNING in bold, capital letters
  • The name of at least one listed chemical
  • Direction to the P65Warnings.ca.gov website
  • Text no smaller than 6-point font (12-point is recommended)
  • Bilingual text in English and Spanish if the dealer uses Spanish on other signage

This is where US Auto Supplies' Proposition 65 Stickers come in. These compliant, face-adhesive decals are printed on durable 3 mil vinyl, bilingual in English and Spanish, and designed to adhere to the inside of the driver's side window while remaining visible from the outside. Each pack contains 100 stickers - ideal for high-volume lots - and most orders ship same-day or next business day. 

Pro tip: Using outdated Prop 65 stickers (pre-August 2018 language) is a violation in itself. The updated version has been required since August 30, 2018. Make sure every vehicle on your lot has the current language. 

Showroom and Lot Signage

Beyond vehicle stickers, dealerships must also post Prop 65 warning signs in the showroom, on the lot, and in the parts department. These signs:

  • Must be at least 4 x 4 inches in size
  • Must use no smaller than 20-point type (72-point recommended for general area postings)
  • Must be placed where customers are likely to see, read, and understand them
  • Must be provided in every language used on other posted signs

Smoking Area Warnings

If your dealership maintains a designated smoking area for employees or customers, an additional Prop 65 warning sign is required. It must be:

  • 8.5 x 11 inches in size
  • No smaller than 22-point font
  • Enclosed in a border box
  • Posted at the entrance to and within the smoking area

Online and Catalog Sales

Dealers who list vehicles or vehicle products for sale online or in catalogs must also include Prop 65 warnings in those listings. OEHHA has clarified internet and catalog warning requirements as part of the 2025 amendments: warnings must be clear, conspicuous, and visible before the point of purchase.

Proposition 65 Requirements for Auto Repair Shops and Body Shops

Auto repair and body shops face Prop 65 obligations from multiple angles: the vehicles they service, the parts they handle, and the chemicals they use in the shop environment.

Vehicle Parts Warnings

During service intake and parts sales, customers and technicians are exposed to chemicals in:

  • Brake components
  • Batteries and electrical parts
  • Gaskets and seals
  • Floor mats and interior parts
  • Cables and wire coverings (phthalates)
  • Lead-containing parts

As of December 2024, OEHHA introduced new tailored safe harbor warnings specifically for motor vehicle parts. These require that warning signage be posted at the point-of-sale or service counter where parts are displayed or sold, in at least 20-point type, and include:

"WARNING: Handling passenger or off-highway motor vehicle parts can expose you to chemicals such as phthalates and lead, which can cause cancer and reproductive harm. To minimize exposure, service the vehicle in a well-ventilated area, wear gloves, and wash your hands. For more information see www.P65Warnings.ca.gov/motor-vehicle-parts."

Repair Order Warnings

Dealers and shops are encouraged — and in some cases effectively required — to include Prop 65 warning language on the back of repair orders. This provides an additional layer of documentation and consumer notification at a key transaction touchpoint.

US Auto Supplies carries a wide selection of auto repair work orders and forms and service inspection forms suited to dealerships and independent shops. Adding Prop 65 language to your repair order stack is one of the simplest ways to build in consistent compliance across every service transaction.

Workplace Chemical Warnings (HAZCOM)

If your shop uses or stores chemicals that contain Prop 65-listed substances, which virtually every shop does,you also have obligations under OSHA's Hazard Communication Standard (HazCom). This means:

  • A written Hazard Communication Program
  • Safety Data Sheets (SDS) accessible to all employees
  • Employee training on chemical hazards
  • Prop 65 warning signs posted in chemical storage areas, break rooms, and other relevant spaces

The 2025 Prop 65 Amendments: What's Changing and When

Prop 65 is not static. California approved significant amendments in late 2024, and they began taking effect January 1, 2025. Here's what dealers and shops need to know:

Short-Form Warning Labels Now Require Chemical Names (by January 1, 2028)

Previously, short-form warnings could be generic and listing no specific chemical. As of the 2025 amendments, short-form labels must now identify at least one specific Prop 65-listed chemical causing the relevant health risk. The phase-in deadline for products manufactured and labeled after that date is January 1, 2028, but businesses can adopt the new language now.

Acceptable new short-form language includes:

  • "Can expose you to [chemical name], a carcinogen and reproductive toxicant. See www.P65Warnings.ca.gov."
  • "Risk of cancer and reproductive harm from exposure to [chemical name]. See www.P65Warnings.ca.gov."

Businesses may also now use "CA WARNING" or "CALIFORNIA WARNING" in addition to "WARNING."

New Motor Vehicle Parts Safe Harbor Language

December 2024 also brought tailored safe harbor warning language specifically for passenger and off-highway vehicle part - meaningful development for any shop or dealership that sells or installs parts. Using this specific language gives businesses the greatest legal protection from private enforcement actions.

Penalties for Non-Compliance: The Risk Is Real

Prop 65 enforcement is aggressive. The California Attorney General, district attorneys, city attorneys (in cities over 750,000), and private individuals and law firms can all file enforcement actions.

Private enforcement lawsuits, sometimes called "headhunter suits" are common, and defendants frequently settle to avoid litigation costs even when violations are minor or disputed. By 2024, annual Prop 65 settlement totals had grown to over $101 million across more than 1,300 settlements.

Fines can reach $2,500 per violation per day. With an active vehicle inventory, that math gets costly fast. And unlike many regulatory frameworks, there is no cure period , once a notice of violation is filed, the clock starts immediately.

Staying compliant is far less expensive than the alternative.

Your Prop 65 Compliance Checklist for Dealerships and Auto Shops

Use this checklist to audit your current compliance status:

California Proposition 65
Compliance Checklist for Auto Dealers & Shops
Use this checklist to audit your dealership or auto shop's Prop 65 compliance status
# Compliance Item Notes / Requirements
🚗  VEHICLE INVENTORY  -  Dealerships
1 Current Prop 65 window sticker on every NEW vehicle Updated 2018+ language required. Pre-2018 stickers = violation.
2 Current Prop 65 window sticker on every USED vehicle Both new and used vehicles on the lot require stickers.
3 Current Prop 65 window sticker on every LOANER vehicle Loaner/courtesy vehicles are included in the requirement.
4 Sticker placed on INSIDE of driver's side window, facing OUT Must be visible from outside the vehicle. Min. 6-pt font (12-pt recommended).
5 Sticker printed in BOTH English and Spanish Bilingual requirement applies when other signage is multilingual.
🏢  SHOWROOM & LOT SIGNAGE  -  Dealerships
6 Warning signs posted in showroom, sales lot, and waiting areas Must be conspicuous and likely to be seen by customers.
7 Signs are at least 4×4 inches with 20-point type minimum General area signs recommended at 72-point font.
8 Signs identify at least one listed chemical (e.g., benzene, phthalates) Generic 'chemicals' language alone is insufficient.
9 Multilingual signage if other premises signs use multiple languages Each language version of other signage requires a matching Prop 65 sign.
🔧  SERVICE & PARTS DEPARTMENT  - Auto Shops & Dealerships
10 Prop 65 warning posted at parts sales counter / service intake Sign at least 5×5 in, 20-pt type. Use OEHHA motor vehicle parts language.
11 Warning language on or accompanying repair orders Include Prop 65 language on back of ROs as best practice.
12 Employee training on chemical hazards completed and documented Required under OSHA HazCom Standard (29 CFR 1910.1200).
13 Safety Data Sheets (SDS) accessible to ALL employees Must be readily available during all work shifts.
14 Written Hazard Communication (HazCom) Program on file Required for shops storing or using listed chemicals.
🚬  SMOKING AREAS  - (If Applicable)
15 Warning sign posted at ENTRANCE to each smoking area Required if smoking areas exist for employees or customers.
16 Warning sign posted WITHIN each smoking area Sign must be 8.5×11 in, 22-pt font minimum, enclosed in a border box.
💻  ONLINE & CATALOG SALES  - (If Applicable)
17 Prop 65 warnings included in online vehicle and parts listings Required for e-commerce sales into California.
18 Warnings visible BEFORE point of purchase 2025 amendments clarified internet/catalog warning placement rules.
📋  ONGOING COMPLIANCE  -  All Businesses
19 Monitor OEHHA for annual updates to the Prop 65 chemical list List updated at least annually. Subscribe to OEHHA notifications.
20 Review sticker and signage language for 2028 short-form requirements New chemical-specific short-form labels required by Jan. 1, 2028.
21 Maintain documentation: photos, training logs, HAZCOM program Documentation is critical defense in any enforcement action.
22 Consult legal counsel if a 60-day notice of violation is received No cure period. Fines up to $2,500/violation/day. Act immediately.
 
Source your Prop 65 stickers & dealership compliance supplies at  usautosupplies.net  |  888-928-2768

Stock Up on Compliant Prop 65 Supplies at US Auto Supplies

Staying compliant starts with having the right materials on hand. US Auto Supplies offers the supplies California dealers and shops need to meet Prop 65 requirements and keep their operations running smoothly:

  • Proposition 65 Warning Stickers — 100 per pack, bilingual, face-adhesive, 4"x4", 3 mil vinyl. Current 2018+ language. Ships same day or next business day.

  • Dealer Addendum Labels — Additional window sticker options for vehicle inventory management and disclosure compliance.

  • Auto Repair Work Orders and Racks — Repair order forms where Prop 65 language can be incorporated into your service workflow.

  • Service Inspection Forms — Multi-point inspection checklists and worksheets that help document thorough service practices.

  • Oil Change and Service Reminder Stickers — Keep customers informed and returning for service with reminder decals used alongside Prop 65 stickers.

  • Buyer's Guide Forms — FTC-required buyer's guides for used vehicle sales, part of a comprehensive compliance approach alongside Prop 65 notices.

  • Night Drop Envelopes — After-hours service intake that can include Prop 65 language for full-cycle customer communication.

If you have further questions about dealership and auto shop requirements or supplies, check out our comprehensive FAQ page.

When did the current Prop 65 sticker language take effect?

August 30, 2018. Stickers using older language are non-compliant and could expose your dealership to enforcement action. Make sure your current inventory uses the updated version.

Summary: Prop 65 Compliance Is an Ongoing Responsibility

California's Proposition 65 is one of the most active consumer protection laws in the country, and the automotive industry is squarely in its scope. For dealerships and auto shops, compliance means:

  • Applying current, bilingual warning stickers to every vehicle on the lot
  • Posting appropriate warning signage in showrooms, lots, service counters, and smoking areas
  • Including Prop 65 language in repair orders and online listings
  • Training employees on chemical hazards and maintaining HAZCOM documentation
  • Staying current with the evolving list of regulated chemicals and updated safe harbor language

The 2025 amendments and the January 2028 deadline for new short-form label language mean the regulatory environment is actively shifting. Proactive compliance, rather than reactive damage control, is the only sensible approach when fines can run $2,500 per violation per day with no cure period.

US Auto Supplies has everything California dealers and service centers need to stay compliant and stocked. Start with our Proposition 65 Warning Stickers:: ordered in bulk, shipped fast, and built to meet California's current requirements.

This article is for informational purposes only and does not constitute legal advice. Proposition 65 is a complex law and compliance requirements vary based on individual business circumstances. Consult qualified legal counsel for guidance specific to your situation.

Sources: California OEHHA (oehha.ca.gov), P65Warnings.ca.gov, SEMA, California New Car Dealers Association (CNCDA), Spencer Fane LLP

 

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