Non-Compliance of Footwear, Bags with California Proposition 65

In December 2025, a total of 403 60-Day Notices of Violation were issued under the U.S. California Proposition 65. The non-conformities were mainly attributed to various toxic and hazardous cheMICal substances, among which excessive lead became the primary cause of non-compliance.

Many light industrial products, including footwear, bags and luggage, glassware and ceramics, were listed. Export enterprises are advised to focus on the chemical substance control of relevant product categories.

Key Data: Lead Accounts for Over 60%, Becoming the Major Non-Compliance Issue

By chemical substance category, the violation notices showed obvious concentration characteristics:

1. Lead: 269 notices, accounting for 66.75%, the primary non-compliant chemical substance;

2. Phthalates: 52 notices, accounting for 12.9%, the second leading cause of non-compliance;

3. Other chemical substances: 81 notices, accounting for 20.1%, including perfluorooctanoic acid, BISphenol A, etc.;

4. Lead + Phthalates: Only 1 notice, accounting for 0.25%, indicating very few cases involving both substances.

Key Product Categories: Detailed Breakdown of Product Non-Compliance Issues

The 403 notices coveRED mULtiple categories such as bags and luggage, glassware and ceramics, footwear, personal care products, etc.

The non-compliant chemicals varied by product, with details as follows:

1. Glass and ceramic products with external decorations: High-risk category for excessive lead, with 26 lead-related violation notices;

2. Bags and luggage products: High incidence of phthalate violations (17 notices), plus 2 notices for perfluorooctanoic acid (PFOA) and 1 notice for bisphenol A (BPA);

3. Footwear products: 1 notice for phthalates and 1 notice for bisphenol A (BPA);

• Beauty and personal care products: Dental floss, facial masks, cleansing foams received 4 notices for other chemicals (diethanolamine, perfluorooctanesulfonic acid (PFOS), titanium dioxide); 1 lead-related notice for sunscreen due to excessive lead;

• Gloves: 2 notices, involving hexavalent chromium and phthalates respectively;

• Textiles: 1 notice for perfluorooctanesulfonic acid (PFOS) detected in shirts;

• Miscellaneous categories (jackets, bags, shower curtains, etc.): Jackets, bags, shower curtains, personal accessories, durable baby and children’s products, pet products received a total of 22 notices for perfluorooctanoic acid (PFOA);

• Other special categories: 15 notices for bisphenol S (BPS) in receipts; 1 lead-related notice for magnifying glass necklaces due to excessive lead; 2 notices for bisphenol A (BPA) for bags and luggage + footwear combined.

Industry Warning: Export Enterprises Should Strengthen End-to-End Control

California Proposition 65 imposes strict regulations on hazardous chemicals such as carcinogens and reproductive toxicants. New regulations have officially taken effect since 2025.

Although a three-year transition period is provided, the December 2025 violation data has sounded the alarm for export enterprises.

Enterprises should strengthen end-to-end management covering raw material testing, production process control, and finished product inspection for high-frequency non-compliant chemicals including lead, phthalates, per- and polyfluoroalkyl substances, bisphenol compounds, etc.

Special attention should be paid to key categories such as glassware and ceramics, bags and luggage, and baby and children’s products to avoid trade disputes caused by excessive chemical substances.