2026 California Prop 65 Regulations and Warnings

Against the backdrop of Sino-US trade frictions, California Proposition 65 (Prop 65 / Ca65 for short) has become a non-negligible compliance barrier in cross-border trade. In 2023 alone, settlement amounts arising from violations of this regulation exceeded USD 30 million, involving many industries such as electronic products, toys, and food contact materials.

What is California Proposition 65?

California Proposition 65, also known as the Safe Drinking Water and Toxic Enforcement Act of 1986, mainly aims to address exposure to toxic chemicals known to the State of California to cause cancer, birth defects, or other reproductive harm.

Proposition 65 requires businesses to provide “clear and reasonable” warnings on consumer products to alert individuals before exposure occurs.

Warning requirements under Proposition 65 were revised (effective August 30, 2018) to expand the legal obligations of businesses. Under Proposition 65, businesses (including manufacturers, distributors, and retailers) must provide “clear and reasonable” warnings to consumers and downstream manufacturers for products containing chemicals listed in the Proposition 65 chemical list.

In addition to warnings displayed on products, required warnings must also be included in ordering catalogs (where purchases can be made), web pages, or checkout pages on internet/e-commerce websites, so that California consumers can view the warning before purchase.

How Does Sensata Technologies Respond to Proposition 65?

To comply with this regulation, Sensata Technologies has assessed that many of its products contain substances listed in the Proposition 65 list and therefore require such warnings. These chemicals include, but are not limited to, nickel, lead, cadmium, and beryllium.

Sensata Technologies has decided to affix warning labels at required locations on the packaging of each product to alert our direct and indirect customers.

Although Proposition 65 only applies to California, we sell to many companies that use Sensata Technologies products in their own products (which are then sold to markets worldwide). If warnings regarding materials in our products are required, Sensata Technologies has a duty to notify other manufacturers and distributors to whom we sell our products, so that they can provide appropriate warnings when they ultimately sell products to California.

Top 3 Compliance Risk Zones for Enterprises

1. Highly Concealed High-Risk Substances

￮ Heavy metals: lead (PVC stabilizer), cadmium (coating pigment)

￮ Plasticizers: DEHP (cable insulation), BPA (inner coating of food cans)

￮ Accidental presence: phthalates (TPR shoe soles), formaldehyde (textile fixing agent)

2. Identification of Special Exposure Scenarios

￮ Oral contact: children’s products, tableware, cosmetics

￮ Skin contact: gloves, clothing accessories

￮ Inhalable dust: printer toner, building materials

3. New Warning Label Rules (Effective 2025)

￮ Short format: ⚠️ icon + “Contains [chemical name]” (for e-commerce detail pages)

￮ Long format: Must include the official OEHHA website link (for physical product labels)

4-Step Scientific Compliance Solution

STEP 1 Intelligent Pre-Screening

• Compare risk points of more than 200 common product categories through an in-house substance database (e.g., mandatory phthalate testing for PVC materials)

• Provide the Bill of Materials (BOM) Declaration Guide to reduce ineffective testing costs

STEP 2 Accurate Exposure Simulation

Laboratory reproduction of real scenarios:

• Microwave heating (food containers)

• Artificial sweat immersion (jewelry)

• Abrasion testing (tire brake pads)

STEP 3 Legal-Level Report Output

• Includes calculation of NSRL/MADL threshold values

• Bilingual Chinese and English versions, directly usable for Amazon appeals

STEP 4 Continuous Compliance Monitoring

• Quarterly list update alerts

• Alternative substance recommendation services (e.g., lead-free solder solutions)

Prop 65 compliance is not simply “labeling”, but a full-process risk control system that runs through product design, supply chain management, and marketing promotion.

JJR LAB recommends enterprises establish a “preventive compliance” mechanism to avoid passive litigation.

Contact our regulatory experts now to obtain the California Proposition 65 High-Risk Product List and response strategies!

For more information:

• Proposition 65 Link: https://oehha.ca.gov/proposition-65

• Proposition 65 Chemical List: https://oehha.ca.gov/proposition-65/proposition-65-list