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California Proposition 65 Reformulation of DINP in Consumer Products

SafeGuardSCosmetics Personal Care and Household, EE Restricted Substances, Footwear and Leather Products, Jewelry Bags and Accessories, DIY Tools and Hardware, Home Furnishings and Houseware, Sports and LeisureMarch 26, 2020

Multiple Prop 65 settlement agreements and judgments have been reached for DINP in a variety of products. Many of these 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. This unique right-to-know law 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 approximately 900 chemicals.

Unless specifically exempted, companies doing business in California have been required to provide ‘a clear and reasonable warning’ before knowingly and intentionally exposing anyone to diisononyl phthalate (DINP) since December 2014.

Multiple Prop 65 settlements and judgments have been reached for DINP in a variety of consumer products. These include, inter alia, electrical items, footwear, hanging storage bags, household sundries, inflatable ring cushions, massage products and tools.

Highlights of these settlements and judgments are summarized in Table 1. The parties in these settlements and judgments agreed to a reformulation of no more than 0.1% (1,000 ppm) DINP and many allow a Prop 65 warning as an alternative.

EntryScopeReformulation/warning for DINP
1Audio wireless FM transmitters< 0.1% otherwise warning
2Bath sponge kits/cases/totes≤ 0.1% otherwise warning
3Brush sets
≤ 1,000 ppm otherwise warning
4Cast protectors
≤ 0.1% otherwise warning
5Cellphone wallets
≤ 0.1% otherwise warning
6Eyebrow grooming kits
≤ 0.1% otherwise warning
7Fishing nets
≤ 0.1% otherwise warning
8Gift wrap organizer with vinyl/PVC components
≤ 0.1% otherwise warning
9Hanging storage bags
≤ 0.1% otherwise warning
10Heat ceramic styling iron products with plastic cables
≤ 1,000 ppm otherwise warning
11High heels/shoes≤ 0.1% otherwise warning
12Inflatable ring cushions
≤ 0.1% otherwise warning
13Knife bags
≤ 0.1% otherwise warning
14Photo albums
< 0.1% 
15Plastic bags containing float papasan products
≤ 1,000 ppm otherwise warning
16Plastic handled coin tong products
≤ 1,000 ppm otherwise warning
17Plastic planted pot products
≤ 1,000 ppm otherwise warning
18Plastic or foam massager/recovery items 
≤ 1,000 ppm otherwise warning
19Plastic or rubberized tools used for framing of pictures or other crafts
≤ 1,000 ppm otherwise warning
20Ponytail straps
≤ 1,000 ppm
21PVC work clothing
≤ 0.1% otherwise warning
22Screwdriver sets
≤ 1,000 ppm otherwise warning
23Shoe flats
≤ 1,000 ppm otherwise warning
24Socks contained in polymer/plastic bags≤ 0.1% 
25Suction cup mirrors
≤ 0.1% otherwise warning
26Swim vests
≤ 0.1% otherwise warning
27Vinyl covered cocktail shakers < 0.1% otherwise warning
28Wallets/credit card holders
≤ 0.1% otherwise warning

Table 1

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

Throughout a global network of laboratories, SGS can offer comprehensive testing, product assessments and consultancy services related to California Proposition 65 to assist your risk management in your supply chain for consumer goods such as DIYs, electrical and electronics, hardgoods products, juvenile products, and textile & toy products. For further information, please visit our website

For enquiries, please contact:

Hingwo Tsang
Global Information and Innovation Manager
t: (+852) 2774 7420 

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