What Products Are Affected by Prop 65？

What is California Prop 65?

California Prop 65, whose full English name is Proposition 65 (abbreviated as CA Prop 65), is officially known as the Safe Drinking Water and Toxic Enforcement Act of 1986 in the state of California, USA. Commonly referred to as "Proposition 65," it is a list of chemicals known to cause cancer or reproductive harm published by California, updated annually. First released in 1987, the list currently includes over 1,000 naturally occurring and man-made chemicals, such as acrylamide, formaldehyde gas, arsenic, lead, cadmium, mercury, and certain phthalates.

Product Categories Covered by California Prop 65

Jewelry, toys, electronic devices, glass and ceramic materials, food, clothing, pharmaceuticals, agricultural pesticides, dyes, cosmetics, production and construction supplies, etc.

Products Subject to California prop 65 testing

Prop 65 sets limit requirements for products including jewelry, clothing, luggage, sports mats, toys and childcare products, glass and ceramic products, aluminum cookware, bicycles and their accessories, electrical devices, and wires/cables. Lead is the most widely restricted substance.

All products sold in California within the aforementioned scope are subject to Prop 65 requirements. Limits for known harmful chemicals in products vary by substance and product category. These limits are derived from settlement agreements reached in lawsuits filed by consumers or environmental groups against specific products containing toxic chemicals.

Key Points of Certain Settled Cases Regarding Chemical Reformulation Requirements Under California Prop 65

Electronic and Electrical Products

①　Computer cooling fans/computer mice/webcams/speakers: Lead ≤ 100 ppm;

②　Chargers and cables for PDA accessories/USB charger cables: Lead ≤ 100 ppm;

③　Vinyl plastic desk lamp clips: DEHP ≤ 1000 ppm, otherwise a warning label is required.

Textiles and Fashion Accessories

①　Baby care mats/polyurethane foam or other filled products: TDCPP, TDBPP, TCEP each ≤ 25 ppm;

②　Foam mats for children and infants (e.g., mats, cushions, pillows): Shall not contain flame retardants, including but not limited to TDCPP, TCEP, TCPP, TBB, TBPH, TPP, V6, MDPP, DBPP, TBPP, PentaBDE, OctaBDE, DecaBDE;

③　Sunglasses/tablecloths: DEHP ≤ 1000 ppm, otherwise a warning label is required;

④　Vinyl plastic shoulder pads: Lead < 100 ppm; Lead ≤ 1.0 µg per NIOSH 9100 standard; DEHP ≤ 1000 ppm;

⑤　Watch straps and replacement straps: Lead in paint or surface coatings ≤ 90 ppm; Lead in all other materials ≤ 100 ppm.

Furniture

①　Vinyl/PVC drum stools: BBP, DBP, DEHP each ≤ 1000 ppm, otherwise a warning label is required;

②　Vinyl/PVC stools: DEHP < 1000 ppm;

③　Sports equipment and accessories;

④　Fitness exercise balls (including yoga mats and jump ropes): DEHP < 1000 ppm, otherwise a warning label is required;

⑤　Billiard tablecloths/table tennis tablecloths: DEHP < 1000 ppm, otherwise a warning label is required;

⑥　Tennis tablecloths: Lead < 50 ppm; Lead < 1.0 µg per NIOSH 9100 standard; DEHP, DBP, BBP, DIDP, DnHP each < 1000 ppm.

⑦　Others

⑧　Aquarium nets with vinyl plastic/PVC handles: Lead ≤ 100 ppm and DEHP < 1000 ppm;

⑨　Safety non-slip mats for showers, bathtubs, or bathrooms: DEHP ≤ 1000 ppm, otherwise a warning label is required;

⑩　Nail clippers: DEHP ≤ 1000 ppm, otherwise a warning label is required;

⑪　Peelers, flatteners, and cutting tools: DEHP ≤ 1000 ppm, otherwise a warning label is required;

⑫　Vinyl/PVC handles for hand tools: DEHP ≤ 1000 ppm, otherwise a warning label is required;

⑬　Adhesive bandages: DEHP ≤ 1000 ppm;

⑭　Books with vinyl/PVC covers: DEHP ≤ 1000 ppm;

⑮　Bottle stoppers: DEHP ≤ 1000 ppm;

⑯　Eyelash curlers and tweezers with handles: BBP, DBP, and DEHP each ≤ 1000 ppm; Lead < 90 ppm; Lead ≤ 1.0 µg per NIOSH 9100 standard;

⑰　Car dashboard trays/clips/tube pins/can and bottle openers/glass cutters/kitchen utensils/paper clips/rubber-handled flashlights/stainless steel kitchen knives/suction cup hooks/tape measures/steering wheel covers: Lead ≤ 100 ppm and DEHP < 1000 ppm, otherwise a warning label is required;

⑱　Photo frames: Lead ≤ 100 ppm;

⑲　Vinyl plastic floor tiles: BBP < 1000 ppm.

Warning Labels

Proposition 65 requires California businesses to notify California consumers if they know their consumer products, food, drugs, or other products contain significant amounts of regulated chemicals. A common way to comply is to attach a warning label to the product, which may include the following statement: "WARNING: This product contains chemicals known to the State of California to cause cancer, birth defects, or other reproductive harm."

However, California now requires more detailed information in warnings, including the names of chemicals and how to avoid or reduce exposure to listed chemicals. Additionally, OEHHA (Office of Environmental Health Hazard Assessment) has proposed establishing a dedicated website to provide the public with more "supplementary information" about chemicals on the Prop 65 list, which will be reflected in warning labels.

How to Meet California Prop 65 Requirements

①　Understand the product's composition and compare it with the Prop 65 list;

②　Clarify the product's production and exposure pathways, and assess the product's risk level;

The above two points mainly target the evaluation of over 1,000 substances.

For California Prop 65 compliance: Based on the product category, select the applicable Prop 65 cases, and test for controlled harmful substances in accordance with case requirements. Case numbers are specified by the customer.