(CLOSED) Comments on Original Proposal for Amendments to Regulations Clear and Reasonable Warnings, Safe Harbor Methods and Content California Code of Regulations

• Proposal will require updates to hundreds of labels for initial changes and will result in regular updating on an ongoing basis whenever product ingredients change. Higher operating costs may create inflationary pressures and could reduce product selection and availability for consumers in California if higher administrative costs cannot be justified for lower volume or niche products. • Proposed 2-year transition period is too short given the breadth of changes required. If OEHHA decides to move forward with amendments despite objections, a transition period of 5 years would be substantially less disruptive and would allow businesses to manage change in conjunction with other product or packaging initiatives, thereby reducing overall transition costs. • New sections related to Passenger or Off-Highway Motor Vehicle Parts as well as Recreational Marine Vessel Parts appear to be redundant with amendment requirements for lubricant products. Please consider that lubricants be excluded from these sections, similar to chemicals, tires, etc. If that recommendation is rejected, rule should provide some latitude for producers and brands to use their standard precautionary language if substantially similar to new language in amendment. Thank you for the opportunity to share feedback on this proposal.