What are you looking for?

California Proposition 65: Reformulation of Chemicals in Consumer Goods

SafeGuardSFood Contact Material, Sports and Leisure, Home TextilesJuly 16, 2021

Several Prop 65 settlements have been reached for consumer products containing BPA, formaldehyde or lead. 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. 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 include approximately 900 chemicals.

Among the list of chemicals is bisphenol A (BPA, CAS 80-05-7), which has been on the Prop 65 list since 2015, formaldehyde (gas, 1988), and lead (1987).

Under Prop 65, companies doing business in California must 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 several settlements involving the three aforementioned chemicals in certain consumer goods (Table 1).




1Bamboo bed sheet sets and bamboo pillowcase sets≤ 40 μg formaldehyde gas per 8 hours of expected use, otherwise warning
2Drain plugs< 1000 ppm lead, otherwise warning
3Duck callsBPA-free, otherwise warning
4Food containers/storageBPA-free, otherwise warning
5Garments≤ 75 ppm formaldehyde (ISO 14184-1) – garments must comply with the Oeko-tex 100 standard in effect at the time of manufacturing
6Padlock keys< 1000 ppm lead, otherwise warning

Table 1

SGS is committed to providing information about development in regulations for consumer products as complimentary services. Through a global network of laboratories, SGS provides a wide range of services including physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer 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 

© SGS Group Management SA - 2021 - All rights reserved - SGS is a registered trademark of SGS Group Management SA. This is a publication of SGS, except for 3rd parties’ contents submitted or licensed for use by SGS. SGS neither endorses nor disapproves said 3rd parties contents. This publication is intended to provide technical information and shall not be considered an exhaustive treatment of any subject treated. It is strictly educational and does not replace any legal requirements or applicable regulations. It is not intended to constitute consulting or professional advice. The information contained herein is provided “as is” and SGS does not warrant that it will be error-free or will meet any particular criteria of performance or quality. Do not quote or refer any information herein without SGS’s prior written consent.

Stay on top of regulatory changes within your industry
Read more articles for the Consumer Goods and Retail industry

News & Insights

  • SGS Headquarters

1 Place des Alpes,

P.O. Box 2152 1211,

Geneva Switzerland