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California Launches Reproductive Toxicity Review for p,p’-Bisphenol Chemicals

Prop65
31
October 2025
•
450
Dr Steven Brennan
OEHHA calls for data on the reproductive toxicity of p,p’-bisphenol chemicals under Proposition 65, signalling potential regulatory action for industry stakeholders.
Epoxy resin
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Summarise this article

California is assessing the reproductive toxicity of p,p’-bisphenol chemicals for potential Proposition 65 listing. OEHHA seeks scientific data from stakeholders, with implications for compliance, labelling, and product safety across multiple industries.

Why is OEHHA reviewing p,p’-bisphenol chemicals under Proposition 65?

The review aims to determine whether p,p’-bisphenol chemicals pose reproductive risks warranting listing under Proposition 65. These substances share structural similarities with BPA, a known endocrine disruptor, prompting regulatory interest in their potential hazards.

What happens if p,p’-bisphenol chemicals are listed under Proposition 65?

If listed, businesses will be required to provide clear warnings for exposures to these chemicals in California. This may affect labelling, material sourcing, and product compliance processes across affected industries.

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The California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA) has launched a public call for scientific data on the reproductive toxicity of p,p’-bisphenol chemicals. Announced on 21 October 2025, the review is part of the process to assess these substances for potential listing under Proposition 65, with public submissions accepted until 1 December 2025.

Proposition 65, formally the Safe Drinking Water and Toxic Enforcement Act of 1986, mandates the state to publish and maintain a list of chemicals known to cause cancer or reproductive harm. OEHHA’s Developmental and Reproductive Toxicant Identification Committee (DARTIC) is responsible for determining whether substances such as p,p’-bisphenols meet the criteria for inclusion.

Scope of Chemicals Under Review

The focus of the review includes p,p’-bisphenols, a group of structurally related compounds used in plastics, epoxy resins, thermal paper, and other industrial applications. These chemicals are structurally similar to bisphenol A (BPA), a compound already under scrutiny for its endocrine-disrupting effects.

OEHHA’s request covers a wide array of p,p’-bisphenol variants, including ethers and esters, that may exhibit similar reproductive hazards. Notably, the agency is not yet declaring these substances harmful, but is instead gathering evidence to inform hazard identification materials.

Evidence and Submissions Sought

Stakeholders are encouraged to submit data from:

  • Animal studies on developmental or reproductive toxicity
  • Epidemiological research in human populations
  • Mechanistic studies on endocrine or developmental disruption
  • Pharmacokinetic and biochemical analyses

Information should be submitted electronically via OEHHA’s website or mailed to the Office of Environmental Health Hazard Assessment in Sacramento. Full submission guidelines are outlined in the official notice.

Implications for Industry and Supply Chains

If listed under Proposition 65, manufacturers, distributors, and retailers using p,p’-bisphenol chemicals in their products may be required to provide consumer warnings and could face restrictions in California. Industries potentially affected include packaging, consumer goods, electronics, and medical device sectors.

Given the structural similarity to BPA and increasing regulatory scrutiny worldwide, the outcome of this review could have far-reaching implications, influencing not only compliance duties but also product reformulation and supply chain transparency strategies.

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