Menstrual products: disposable tampons and pad products: concerning chemicals.

The requirement for manufacturers to maintain chemical concentration information changed from 'on or before December 31, 2026' to 'on or before and after December 31, 2026,' making it a continuing obligation rather than a one-time compliance deadline.

A new paragraph (b)(2) exempts the department's determination of additional chemicals of concern from the Administrative Procedure Act, meaning the department can designate new chemicals without going through formal rulemaking procedures such as public comment and notice requirements.

Subdivision (b) now specifies that the department determines additional chemicals 'from its list of candidate chemicals,' adding a constraint that limits the source pool for designations to a pre-existing candidate list rather than any chemical the department identifies.

The phrase 'concerning chemicals' is inserted alongside 'chemicals of concern' throughout the bill (e.g., 'concerning chemicals of concern'), which appears to introduce a parallel or overlapping term, though its distinct legal meaning relative to 'chemicals of concern' is unclear from the text.

Cross-reference and grammatical corrections were made: 'subdivision (a) or and (c)' corrected to 'subdivisions (a) and (c),' 'their' changed to 'its,' and subdivision lettering was reorganized for clarity.

Chapter number 604 was assigned and the bill was formally approved by the Governor on October 11, 2025 and filed with the Secretary of State the same day.

Page headers changed from 'SB 754' to 'Ch. 604', page numbers shifted from 93 to 92, and line wrapping was adjusted throughout for the official chaptered publication format.

The term 'chemicals of concern' is replaced with 'concerning chemicals' throughout the entire bill, changing the legal terminology used to describe regulated substances in disposable tampons and pad products.

The effective date language changes from 'on or before and after December 31, 2026' to 'on and after December 31, 2026,' removing the 'or before' component and making it a straightforward prospective requirement.

Specific deadlines for the department to publish lists of acceptable testing methods are removed. The old version required publication by July 31, 2026 (for the four listed chemicals) and by January 1, 2027 (for additional determined chemicals). The new version simply states the department 'may publish' such a list without a deadline.

The department's authority to determine additional concerning chemicals is simplified. The old version allowed two pathways: (1) a finding under Safer Consumer Products Regulations, or (2) a finding that the chemical was present in products AND had adverse public health impacts. The new version removes the Safer Consumer Products Regulations pathway entirely, leaving only the two-criteria test.

Removed the 'on or before January 1, 2027' deadline in subdivision (b)(1) for the department to determine and publish additional concerning chemicals in disposable tampons or pad products. The department can now make this determination at any time without a fixed deadline.

Removed the 'on or before January 1, 2028' deadline in subdivision (c) for the department to require manufacturers to maintain information about concentrations of additional concerning chemicals. The department can now impose this requirement at any time.

The deadline for manufacturers to begin maintaining chemical concentration information was delayed from July 1, 2026 to December 31, 2026, giving manufacturers an additional six months.

A new provision allows the department, on or before January 1, 2028, to require manufacturers to maintain concentration information for any additional chemicals identified under the new authority.

A specific list of four chemicals is now enumerated: lead (CAS no. 7439-92-1), arsenic (CAS no. 7440-38-2), cadmium (CAS no. 7440-43-9), and zinc (CAS no. 7440-66-6). Previously the bill only referenced 'chemicals that the department has found to be of concern' without naming them.

A new provision allows the Department of Toxic Substances Control, on or before January 1, 2027, to determine and publish additional chemicals of concern. The department may use either the Safer Consumer Products Regulations or a two-part finding that the chemical was detected in products and has adverse public health impacts.

The standalone section stating 'It is the intent of the Legislature to enact future legislation relating to menstrual products' was removed entirely.

References to 'menstrual products' were changed to 'disposable tampon or pad products' in several provisions, narrowing the scope of the disclosure and publication requirements to that specific product category.

The fiscal committee designation changed from 'no' to 'yes,' indicating the amendment introduced a state fiscal impact that was not present in the prior version.

The deadline for manufacturers to maintain information about chemical concentrations in their products was extended from July 1, 2026 to December 31, 2026, giving manufacturers approximately six additional months of compliance time.

A new subdivision (d) requires the department to publish on its website a list of acceptable testing methods, frequencies for testing, and appropriate third-party laboratory accreditations. For the four initially listed chemicals (lead, arsenic, cadmium, zinc), this list must be published by July 31, 2026. For additional chemicals determined later, the list must be published by January 1, 2027. The department may update the list as needed.

The term 'pads' was replaced with 'pad products' throughout the bill to align terminology and clarify the scope of covered products.

Manufacturers of disposable tampons or pads must maintain information on concentrations of chemicals that DTSC has found to be of concern in their products, effective no later than July 1, 2026.

Upon request from DTSC, manufacturers must provide technical documentation including test methods and analytical test results assessing chemical concentrations in their menstrual products.

DTSC may provide information about potential health impacts of specific chemicals in menstrual products to the public in a searchable format on its internet website.

DTSC is authorized to conduct its own tests or contract with third-party laboratories to confirm manufacturer-reported results, giving the department independent verification power.

DTSC may publish analytical test results received from manufacturers or obtained through its own testing, along with departmental analysis of those results.

Manufacturers must pay for testing costs before testing is conducted, and all charges collected are deposited into the T.A.M.P.O.N. Act Fund, available upon legislative appropriation for implementation purposes including chemical testing administration and compliance oversight.

The bill's title was changed from a generic 'An act relating to public health' to specifically reference adding Section 25258.7 to the Health and Safety Code, and the digest was expanded to describe the new regulatory requirements rather than just the legislative intent statement.