California Proposition 65 restricts more than 800 chemicals and heavy metals, including lead, cadmium, and phthalates. Further, California Proposition 65 applies to consumer products for all age groups.
In this guide, we explain what Amazon sellers, importers, and manufacturers must know about California Proposition 65 lab testing – including costs, sample submissions, lead times, failed test results, and more.
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What is California Proposition 65 lab testing?
California Proposition 65 lab testing broadly refers to the process to analyze whether a certain material is compliant with California Proposition 65. Materials containing CA Prop 65 restricted substances above the set limits are non-compliant.
How do I know which substance tests to include?
California Proposition 65 restricts hundreds of chemicals and heavy metals known to cause reproductive harm, birth defects, and cancer. As an importer, manufacturer, or Amazon seller, you don’t necessarily need to keep track of all CA Prop 65 restricted instances.
Instead, you can consult a lab testing company to help you assess which chemicals and heavy metals to include in your testing process. Testing companies generally require the following information in order to make this assessment:
- Product name/description
- Product images
- Bill of materials
Likewise, testing companies also stay up to date on the substance limits – which can change – and new substances being added to the list of restrictions.
Example
Below follows an example of a CA Prop 65 test item list:
1. California Prop 65 Total Cadmium (Cd) Content: Surface Coating
2. California Prop 65 Total Cadmium (Cd) Content: Substrate
3. California Prop 65 Total Lead (Pb) Content: Surface Coating
4. California Prop 65 Total Lead (Pb) Content: Substrate
5. California Prop 65 Phthalate Content (6P)
Which products may require California Proposition 65 lab testing?
California Proposition 65 can be applied to all consumer products for all age groups. Here are a few examples:
- Apparel
- Watches
- Jewelry
- Electronics
- Kitchen products
- Toys
- Other children’s products
Is California Proposition 65 applicable to children’s products?
Yes, California Proposition 65 testing is also relevant for toys and other children’s products. That said, unlike CPSIA, California Proposition 65 is not only applicable to children’s products – but covers consumer products for all age groups.
California Proposition 65 lab testing costs
California Proposition 65 testing costs largely depend on the type of materials. For example, additional phthalates testing is necessary for PVC and other plastics. This increases the number of tests necessary, which therefore impacts the California Proposition 65 lab testing cost.
The number of different materials also impacts the testing costs. As such, a watch constituting of many different parts and materials is more expensive to test than a t-shirt made using a single fabric.
California Proposition 65 Quotation Example
| Test | Cost (USD) |
| California Prop 65 Total Cadmium (Cd) Content: Surface Coating | $20 |
| California Prop 65 Total Cadmium (Cd) Content: Substrate | $40 |
| California Prop 65 Total Lead (Pb) Content: Surface Coating | $20 |
| California Prop 65 Total Lead (Pb) Content: Substrate | $55 |
| California Prop 65 Phthalate Content (6P) | $310 |
| Total | $445 |
How many samples do we need to submit?
When it comes to consumer products, such as apparel and jewelry, testing companies often require that you submit somewhere between 5 to 10 pcs. As such, you may want to consider ordering a few units extra from your supplier.
How long does the test take?
California Proposition 65 lab testing normally takes 1 to 2 weeks. Note that this does not include the time it takes to submit samples to the lab.
Can I get a test report from our manufacturer?
It’s very rare that manufacturers and trading companies in China and other countries can provide pre-existing California Proposition 65 lab test reports for their products and materials. Instead, it’s almost always necessary to arrange lab testing before you import and sell consumer products in California.
Further, manufacturers generally don’t have the expertise or equipment to conduct their lab tests.
Is California Proposition 65 testing required for Amazon sellers?
Amazon sometimes requires sellers to include a California Proposition 65 warning in their product listings. In such cases, Amazon also requires that the seller identifies the chemicals that the product may contain. While not mentioned in the Amazon Seller Central, this in turn normally requires third-party lab testing – as you otherwise cannot identify these chemicals.
Further, it’s not mentioned if sellers that can provide valid California Proposition 65 are exempt from such warnings.
What happens if my product fails California Proposition 65?
Products that fail California Proposition 65 testing contain excessive amounts (above the set limit) of at least one restricted substance. Chemicals and heavy metals cannot be ‘cleaned’ or ‘removed’. Hence, the product may need to be discarded.
One way to avoid this is by submitting materials for California Proposition 65 testing prior to final product assembly.
California Proposition 65 test report sample
Do you have to retest for P65 for ongoing (evergreen) product if nothing about the product has changed?
What test method is accepted for Cal Prop 65 testing? Does it have to be a CPSC accredited test method and / or test lab?