SAFEGUARDS | Consumer Products NO. 127/15

Proposition 65 (Prop 65) is the ‘Safe Drinking Water and Toxic Enforcement Act of 1986’, a ballot initiative passed overwhelmingly by California residents in 1986. Since its enactment, there have been numerous lawsuits which resulted in the reduction of carcinogenic and reproductive chemicals by reformulations of consumer products containing such chemicals. 

Prop 65 [1] is now over 28 years old and has been effective in reducing exposures to toxic chemicals. Even though the Prop 65 list contains 850 or so chemicals, lead-containing consumer products [2] have been consistently targeted over the years. 

Since late 2014, a number of Prop 65 settlements have been reached for the reformulation of heavy metals in a variety of products, including but not limited to

  • Cadmium and lead in exterior designs in jars, ring holders, and salt and pepper shakers
  • Lead in glass containers with exterior designs for bath products
  • Tire pressure gauges

It is interesting to note that releasable cadmium using NIOSH 9100 [3] (Ghost Wipe) is one of the reformulation requirements for exterior decorations in jars, ring holders as well as salt and pepper shakers. This test method is specifically intended for releasable lead. The adoption of this method for releasable cadmium may set a precedent for future Prop 65 agreements involving releasable heavy metals.

Highlights of these settlements for heavy metals are summarized in Table 1.

table 1


Heavy Metal






Exterior designs:

  • -Jars
  • Ÿ-Ring holders
  • Ÿ-Salt and pepper shakers

≤ 1.0 μg each of lead and cadmium (NIOSH 9100) and

≤ 90 ppm each of lead and cadmium and

≤ 0.99 ppm each of lead and cadmium (ASTM C 927-99, total immersion with results corrected for internal volume)



Car accessories:

  • Interior LED lights and lightings

≤ 100 ppm otherwise warning



Glass containers with exterior designs for bath products, including bath salts, lotions and soaps.

≤ 90 ppm otherwise warning



Tire pressure gauges

≤ 100 ppm and

≤ 1.0 μg (NIOSH 9100) otherwise warning

Throughout our global network of laboratories, we are able to provide a range of services, including analytical testing and consultancy for heavy metals and other restricted substances in consumer products for California and international markets. Please do not hesitate to contact us for further information.

For enquiries, please contact:

Hing Wo Tsang
Global Toys and Juvenile Products
t: +852 2774 7420

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