What Chemicals Are Tested Under California Proposition 65?

California Proposition 65, formally known as Proposition 65or CA65, is also referred to as CP65 certificationor Prop65 certification. The official name of Proposition 65 is the Safe Drinking Water and Toxic Enforcement Act of 1986. This California law requires businesses to provide warnings when their products expose consumers to chemicals identified by the state as causing cancer, birth defects, or other reproductive harm.

This standard is somewhat complex, mainly targeting chemicals that may pose health risks. The California government updates the list of regulated chemicals annually. Currently, nearly 1,000 chemicals known to cause cancer, birth defects, or reproductive harm are included. If a product contains any of these chemicals and could expose consumers during normal use, a warning label is required; failure to comply could result in lawsuits and significant penalties.

What Chemicals Are Primarily Tested Under California Proposition 65?

- Heavy Metals: such as Lead (Pb), Cadmium (Cd), Mercury (Hg), etc. Lead and cadmium are key substances tested.

- Lead limit: 100 ppm

- Cadmium limit: 200 ppm

- (Note: Limits may vary depending on the product.)

- Phthalates: commonly tested phthalates include DBP, BBP, DEHP, DIDP, DnHP, DINP.

- Limit: 1000 ppm per substance

- Formaldehyde: used in adhesives, coatings, etc. Especially tested in textiles and leather of toys that have direct skin contact.

- Limit: 75 ppm

- Flame Retardants: tested in PU foam materials used in upholstered furniture, cushions, car seats, etc.

- Limit: 2.5 ppm per substance

- Bisphenol A (BPA): commonly used in plastics and resins; tested in food contact products.

- Limit: 1000 ppm

- Other potential substances: including PAHs (Polycyclic Aromatic Hydrocarbons), organic solvents, arsenic (As), and others.

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Warning Label Requirements

If a product contains listed chemicals that pose exposure risks, companies must provide a warning label. Different types of products (e.g., those containing only carcinogens or only reproductive toxicants) have specific warning statements.

Example warning label format:

> “This product can expose you to chemicals including (name of one or more chemicals), which is (are) known to the State of California to cause birth defects or other reproductive harm. For more information go to www.P65Warnings.ca.gov.”

Proposition 65 Testing Standards

For toys and children’s products:

In August 2008, California reached a settlement on limits for lead and phthalates in toys and other children’s products.

- Phthalate-free: The specific product must contain no more than 0.1% (1,000 ppm) of each of DEHP, BBP, DBP, DIDP, DnHP.

- Lead-free:

- PVC components: lead content < 0.02% (200 ppm)

- Accessible non-PVC components: lead content < 0.06% (600 ppm)

Covered products:

- “Toys” designed for or reasonably used by children under 6 years old.

- “Child care articles” designed for or used by children under 3 years old for sleep, relaxation, grooming, feeding, or teething.

> Note:Compliance with the U.S. Consumer Product Safety Improvement Act (CPSIA)does not mean compliance with Proposition 65. Prop 65 includes DnHP, which CPSIA does not mention. Also, Prop 65 requires lead in PVC components not to exceed 0.02% (200 ppm), while CPSIA sets a substrate limit of 0.06% (600 ppm).

Scope of Proposition 65

Proposition 65 covers a wide range of products, including:

- Handbags

- Footwear

- Belts

- Apparel

- Fashion accessories

- Kitchenware

- Brass products

- Sporting goods

- Hand tools

- Furniture

- Electronics

Notably, for Halloween products, Prop 65 emphasizes requirements for arsenic, cadmium, formaldehyde, lead, and phthalates.

Proposition 65 Testing Process

The testing process is straightforward:

1. Identify product type— The lab determines applicable standards and tests.

2. Identify material sampling points— Determine parts and quantity to test.

3. Prepare samples— Submit samples to the lab.

4. Issue report— The lab provides a report if the product passes testing.

Validity of Proposition 65 Reports

Proposition 65 reports generally do not have a fixed validity period, but they are not permanent. Reports must be updated as the law evolves; outdated reports become invalid.

Documentation Required to Apply for Proposition 65 Testing

- 2–3 sets of product samples

- User manual

- Bill of Materials (BOM)

- Certification application form