All companies who do business in the State of California should already be aware of the changes made to the Safe Drinking Water and Toxic Enforcement Act, also known as, Proposition 65, or Prop 65, that will be going into effect on August 30th 2018. While Proposition 65 is not new, there have been recent amendments to the California law which affect the warning requirements on products containing chemicals known to cause cancer, birth defects or other reproductive harm. Of note, the recent amendments impact how warnings must be presented in catalogs and on websites. If you are unaware of these recent changes, please visit https://oehha.ca.gov/proposition-65/about-proposition-65.
The purpose of this email is to notify you that PartsTech plans to be in full compliance with the new Proposition 65 display requirements by August 30th 2018. This notification is to also inform you of what our best practices will be for delivering Proposition 65 information, as well as, what our expectations will be from you the data provider.
PartsTech will follow the best practices that have been defined by Autocare on how to deliver Proposition 65 warnings. If you are unaware of these best practices please visit https://www.autocare.org/What-We-Do/Technology/Resource-Files/PIES—Delivering-Regulatory-Content-Best-Practices/.
A few items to note specific to the use of Autocare best practices for PartsTech:
- PartsTech will NOT accept Proposition 65 warnings in ACES. Proposition 65 information is at the product level, NOT at the vehicle level. PartsTech will NOT accept this information as a note in ACES, or as a digital asset in ACES. Proposition 65 warnings MUST be provided in PIES. If your company does not have the ability to create a PIES export, please contact PartsTech directly for alternative solutions.
- For Proposition 65 warnings that will be provided as a text warning: This information needs to be provided as a product attribute per the Autocare Best Practices. This information should not be provided in other PIES segments.
- For Proposition 65 warnings that will be provided as a digital asset: PartsTech will accept multiple asset formats such as .jpg and .pdf. We will also accept Proposition 65 warnings as a URL.
- Proposition 65 assets should be provided in a separate archive from product images and diagrams. The assets should be provided in a single archive and labeled as to reference Proposition 65.
- All Proposition 65 assets and non PIES mappings should be provided as full/complete updates.
- PartsTech will accept “add only” assets and mappings (meaning new assets and mappings for a part that has never had a Proposition 65 asset or mapping) however, complete updates are preferred.
- In order to provide Proposition 65 warning mappings, or URL’s in PIES, you must follow the PIES Digital Asset Best Practices, in addition to the Autocare Proposition 65 Best Practices for digital assets.
- If you are providing a flat mapping file, include the file with the Proposition 65 assets.
- If providing Proposition 65 information as either text or a digital asset in PIES, PartsTech requires you to label this information as a Proposition 65 warnings. For text warnings, this information can be provided in the AttributeID for those utilizing attributes. This information can also be provided in AdditionalInformation, AssetID, AssetDescriptions, and in the FileName or URL for those utilizing the digital asset segment.
- Acceptable Proposition 65 labels are California Proposition65, California Proposition 65, Proposition65, Proposition 65, Prop65, Prop 65, PR65, PR 65.
- Avoid providing the same Proposition 65 warning in multiple PIES segments for the same product.
While PartsTech expects to be fully compliant with the new Proposition 65 display requirements, PartsTech will be reliant on you, the data provider, to provide the proper warning verbiage for any and all products that fall under the new Proposition 65 requirements.
PartsTech will in no way alter, modify, or add Proposition 65 warnings to any products. It will be the sole responsibility of the data provider to ensure the verbiage is compliant with Proposition 65 requirements and that all products that require a Proposition 65 warning are being provided with this information.
While PartsTech will make any and all reasonable attempts to display all provided Proposition 65 warnings, we will be dependent on the proper mapping and labeling of such Proposition 65 information, as described above, in order to properly convey this information to the customer.
We appreciate your support in this matter and understand you may have questions in regards to Proposition 65 and the transmission of this information. Please reach out to firstname.lastname@example.org with any questions in regards to Proposition 65. Also, please reach out to let us know how you plan to provide Proposition 65 warnings to PartsTech.
PartsTech Data Department