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California Proposition 65: Reformulation of Chemicals in Consumer Goods

SafeGuardSDIY Tools and Hardware, DIY Tools and Hardware, HG Restricted Substances, Sports and Leisure, Stationery and Office Supplies, Personal and Protective EquipmentJanuary 12, 2022

Several settlements have been reached for a variety of goods containing Prop 65 chemicals. Some 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.

Among the list of Prop 65 chemicals:

  • Chromium (VI) compounds are listed as chemicals known to the state of California to cause cancer and reproductive toxicity
  • Bisphenol A (BPA, CAS 80-05-7, reproductive toxicity)
  • N-nitrosodiethylamine (NDEA, CAS 55-18-5, cancer)
  • Perfluorooctanoic acid (PFOA, CAS 335-67-1, reproductive toxicity) 

In this communication, we summarize several settlements involving consumer goods containing the aforementioned chemical(s) (Table 1). It is interesting to note that a reformulation of no more than 10 ppb NDEA in latex resistance bands has been reached (entry 4, SafeGuardS 66/21). Entries 1-3 and 5 agreed to releasable lead as part of the settlement agreement. Additionally, some of these settlements allow a Prop 65 warning as an alternative. 




1Airpod cases≤ 3 ppm BPA otherwise warning
2Gun slings
Warning for chromium (VI)
3Lab set glasses/goggles
BPA-free otherwise warning
4Latex resistance bands
≤ 10 ppb n-nitrosodiethylamine (NDEA) 
5Leather hand grips
Warning for chromium (VI)
6Makeup foundations≤ 0.1 mg/kg PFOA for products in solid form
≤ 0.1 mg/L PFOA for products in liquid form
Products are required not to contain any ingredient that is known to degrade to detectable PFOA, including but not limited to C9-15 fluoroalcohol phosphate

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. In the end, it’s only trusted because it’s tested. Contact us for more information or visit our website

For inquiries, please contact:

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

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