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California Proposition 65: Reformulation of Lead in Consumer Products

SafeGuardSDIY Tools and Hardware, DIY Tools and Hardware, Home Furnishings and Houseware, Sports and LeisureJanuary 11, 2021

Multiple Prop 65 settlements have been reached for lead in a variety of products. Many of these require both lead content and releasable lead as part of the reformulation, or 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 approximately 900 chemicals.

Lead has been listed as a chemical known to cause birth defects and reproductive harm since 1987, and cancer since 1992. 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 lead since February 1988.

Lead and its compounds can be used in a wide variety of consumer goods, including cable sheathings, ceramicware, glassware and similar products, children’s products, paint, products containing vinyl, imitation leather or brass materials, and pigments.

Over the years, lead and phthalates have consistently been targeted in consumer products. Products containing these chemicals account for the majority of settlements and judgments

Several Prop 65 settlements for consumer goods containing lead are summarized in Table 1. It is interesting to note that many of these reformulations require both releasable lead using NIOSH 9100 and lead content, or a Prop 65 warning as an alternative.

EntryScopeReformulation/Warning for lead  
 1Brass hose repair menders≤ 100 ppm otherwise warning
 2Brass mailboxes≤ 300 ppm for alloys otherwise warning
 3Bronze drawer knobs≤ 90 ppm and ≤ 1.0 μg (NIOSH 9100) otherwise warning
 4Ceramic pet bowls with exterior decorationsDecorations, colored artwork, designs and/or markings on the surface of products:
≤ 90 ppm and ≤ 1.0 μg (NIOSH 9100) otherwise warning
 5Diving weights≤ 90 ppm and ≤ 1.0 μg (NIOSH 9100) otherwise warning
 6Golf mats≤ 90 ppm otherwise warning
 7Handheld luggage scales with PVC grips≤ 90 ppm and ≤ 1.0 μg (NIOSH 9100) otherwise warning
 8Mouthpieces used with brass musical instruments≤ 100 ppm otherwise warning
 9Multi-use shopping cart bags≤ 90 ppm and ≤ 1.0 μg (NIOSH 9100)
 10Split shot fishing sinkers≤ 90 ppm and ≤ 1.0 μg (NIOSH 9100) otherwise warning
 11Pet leashes≤ 90 ppm and ≤ 1.0 μg (NIOSH 9100) 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 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. In the end, it’s only trusted because it’s tested. Contact us for more information or visit our website

For enquiries, please contact:

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

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