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California Proposition 65 Reformulation of Chemicals in Consumer Products

SafeGuardSHardgoods, Softlines, Toys and Juvenile Products, Electrical & Electronics, Personal and Protective EquipmentJuly 11, 2023

SG 87/23

Multiple settlements have been reached for a range of consumer goods containing Prop 65 chemicals. Many of these agreements allow a Prop 65 warning as an alternative.

California Proposition 65 (Prop 65) is the ‘Safe Drinking Water and Toxic Enforcement Act of 1986’, a ballot initiative passed overwhelmingly by Californian residents in November 1986. It requires the state to publish a list of chemicals that are known to cause cancer, birth defects and/or reproductive harm. First published in 1987, the list has evolved to more than 900 chemicals.

In Prop 65, one important provision for companies doing business in California is to provide a clear and reasonable warning before knowingly and intentionally exposing anyone to a listed chemical. Unless exempt, businesses have 12 months to comply with this requirement once a chemical is listed.

In this communication, we summarize multiple settlements involving a variety of consumer products containing chromium (VI) (Table 1), lead (Table 2), n-nitrosodiethylamine (NDEA, Table 3) and one or more phthalates (Tables 4a – 4g;). It is interesting to note that ISO 19577 has been designated as the method for the reformulation of NDEA in latex caps for swimming and other water activities (Table 3).

A Prop 65 settlement is a consent agreement between the parties named in the settlement and any party not named in the settlement is not bound by it.


1BBPButyl benzyl phthalate85-68-7
2DBPDi-n-butyl phthalate84-74-2
4DIDPDi-isodecyl phthalate68515-49- 1/26761-40-0
5DINPDiisononyl phthalate---
6DnHPDi-n-hexyl phthalate84-75-3

Table 1

Throughout a global network of laboratories, SGS offers comprehensive testing, product assessment and consultancy services related to California Proposition 65 to help you manage risk in your supply chain for consumer goods such as DIYs, electrical and electronics, hardgoods products, juvenile products, and textile & toy products. Contact us for more information or visit our website. In the end, it’s only trusted because it’s tested.

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