DTSC Candidate Chemicals List: Listing, Obligations, and Review

The DTSC Candidate Chemicals List is a regulatory watchlist of roughly 2,300 substances that California’s Department of Toxic Substances Control tracks as potential hazards in consumer products sold in the state.¹ A chemical’s appearance on it imposes no obligations on manufacturers, triggers no product restrictions, and requires no consumer warnings. The list is the pool from which DTSC selects specific product-chemical combinations for regulation under its Safer Consumer Products program.²

Where the List Comes From

DTSC does not test chemicals itself to build the list. Instead, the agency compiles it from 23 pre-existing authoritative lists maintained by U.S. federal agencies, California state agencies, and international scientific bodies. A chemical qualifies as a Candidate Chemical if it appears on any one of them.³ California Code of Regulations Title 22, Section 69502.3, requires DTSC to publish the compiled list on its website and update it as the underlying sources change.⁴

Fifteen of the source lists focus on hazard traits: carcinogenicity, reproductive toxicity, developmental harm, endocrine disruption, environmental persistence. They come from bodies including California’s Proposition 65 list, the U.S. EPA’s Integrated Risk Information System, the International Agency for Research on Cancer, the European Chemicals Agency, and the National Toxicology Program. The remaining eight track exposure rather than hazard — chemicals showing up in drinking water, air monitoring, or human biomonitoring data. Those include California’s Maximum Contaminant Levels for drinking water, California Toxic Air Contaminants, and the CDC’s National Exposure Report.³

The program’s statutory backbone sits in the 2008 Green Chemistry law, specifically Health and Safety Code sections 25252 and 25253. Section 25252 tells DTSC to consider volume in commerce, exposure potential, and effects on sensitive populations like infants and children, and to draw on work already done by other governments and scientific bodies.⁵ Section 25253 authorizes DTSC to evaluate those chemicals against potential alternatives and, based on the results, to require anything from no action at all to an outright ban.⁶

What Being on the List Does Not Do

This is the point most often misunderstood. A chemical’s presence on the Candidate Chemicals List, standing alone, creates no compliance duty. It does not restrict sales. It does not mandate labeling. It does not require reformulation or disclosure. It does not trigger a warning obligation.⁷ The list identifies chemicals DTSC may eventually scrutinize inside particular products. Nothing more happens until DTSC formally designates a specific product-chemical combination as a Priority Product.

How a Candidate Chemical Becomes an Actual Obligation

The regulatory work begins with Priority Product designation. DTSC can only designate a product-chemical combination as a Priority Product if it falls within a category described in the agency’s current Three-Year Priority Product Work Plan, unless a legislative mandate, executive order, or granted petition provides a separate basis.⁸⁹

Designation happens through formal rulemaking. As of early 2026, out of the roughly 2,300 chemicals tracked, DTSC has designated six Priority Products:

Children’s foam-padded sleeping products containing the flame retardants TDCPP or TCEP
Spray polyurethane foam with unreacted methylene diphenyl diisocyanate (MDI)
Paint and varnish strippers containing methylene chloride
Carpets and rugs containing per- and polyfluoroalkyl substances (PFAS)
Laundry detergents containing nonylphenol ethoxylates (NPEs)
Paint and varnish strippers and graffiti removers containing N-methylpyrrolidone (NMP)

Six products against a 2,300-chemical inventory shows how narrowly the program focuses before creating any duty.¹⁰

What Manufacturers Must Do When a Product Is Listed

Once DTSC finalizes a Priority Product listing, the manufacturer has 60 calendar days to submit a Priority Product Notification through the CalSAFER system. Products introduced into the California market after the listing date face the same 60-day clock running from the date of introduction.¹¹

Within 180 days of the regulation’s effective date, the manufacturer must either submit a Preliminary Alternatives Analysis report or notify DTSC that it will remove the product from California or replace the chemical of concern within 90 days.¹² Safety Data Sheets must be submitted for every component of the product, not just the component containing the chemical of concern. Manufacturers may claim trade secret protection over much of their submission, but hazard trait data and the chemical identity tied to that data cannot be shielded.⁷

The Alternatives Analysis itself runs in two stages. Stage one is screening: identify what the chemical of concern does in the product, propose replacements, and screen out clearly unworkable ones. The Preliminary AA Report includes a workplan and timeline for stage two. Stage two is the in-depth comparison, covering hazard profiles, performance, economic impact, and consumer acceptance. The Final AA Report contains the selection decision and an implementation plan.¹³

What DTSC Can Require After Review

After reviewing the Alternatives Analysis, DTSC picks from a menu of regulatory responses. The program prioritizes reducing hazards over managing exposure, so removing or replacing the chemical is preferred to adding warnings or engineering controls.¹⁴ Available responses include:

No regulatory action.
Additional information to fill gaps DTSC identified.
Consumer labeling that discloses the chemical name, known hazards, and safe handling instructions.
Use restrictions, such as reducing chemical concentration or limiting product access to trained individuals.
Sales prohibition in California if no safer feasible alternative exists and the manufacturer cannot show the product’s benefits outweigh its costs.
Engineering or administrative controls, such as air filtration during manufacturing.
End-of-life management, meaning a product stewardship plan for hazardous waste handling.
Green chemistry research funding when no feasible safer alternative currently exists.

DTSC can combine several of these for a single product, and the specifics are tailored to each Alternatives Analysis rather than applied as a blanket rule.¹⁴

How the List Compares to Proposition 65

The two programs overlap and get conflated. Every Prop 65 chemical is on the Candidate Chemicals List, because the Prop 65 list is one of the 23 authoritative sources DTSC pulls from.⁷ They do different work. Prop 65, run by the Office of Environmental Health Hazard Assessment, requires businesses to warn consumers before exposure to listed chemicals and prohibits discharging those chemicals into drinking water sources, but does not restrict how chemicals are used in products.¹⁵ The Safer Consumer Products program can go further, ultimately forcing reformulation, concentration limits, or removal from the California market. The Candidate Chemicals List by itself, though, sits closer to Prop 65 in one respect: neither the list nor Prop 65 restricts a product’s ingredients on its own.

How to Check the List

CalSAFER is DTSC’s public information system for the Safer Consumer Products program.¹⁶ You can search the Candidate Chemicals List by chemical name or Chemical Abstracts Service number, view currently designated Priority Products, check open public comment periods, and review noncompliance records for manufacturers that missed SCP requirements. Manufacturers use the same system to submit Priority Product Notifications and Alternatives Analysis reports.¹²

One boundary worth flagging: SCP regulations do not require universal ingredient disclosure. Cosmetics, personal care products, and cleaning products already carry separate labeling duties under other laws, but manufacturers of most other product types are not required to disclose ingredients unless the product has been formally listed as a Priority Product.⁷ For a consumer checking whether a specific chemical is on DTSC’s radar, CalSAFER is the reliable public source.

1
Department of Toxic Substances Control. How Many Chemicals Are on the Informational Candidate Chemicals List
2
Department of Toxic Substances Control. Safer Consumer Products
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Department of Toxic Substances Control. Authoritative Lists
4
Legal Information Institute. California Code of Regulations 22 CCR 69502.3 – Candidate Chemicals List
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California Legislative Information. California Code HSC 25252
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California Legislative Information. California Code HSC 25253
7
Department of Toxic Substances Control. Frequently Asked Questions
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Department of Toxic Substances Control. Priority Product Work Plan
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Department of Toxic Substances Control. 2024-2026 Priority Product Work Plan
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Department of Toxic Substances Control. How Will I Know the Initial Priority Products List Is Final
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Department of Toxic Substances Control. Alternatives Analysis Frequently Asked Questions
12
Department of Toxic Substances Control. Priority Products
13
Department of Toxic Substances Control. Introduction to the Alternatives Analysis Process
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Department of Toxic Substances Control. Regulatory Response
15
OEHHA. Proposition 65 List
16
Department of Toxic Substances Control. CalSAFER