List of Products Covered by California Proposition 65: An Overview

California Proposition 65 sets substance restrictions and warning labeling requirements for products sold in California. You must either ensure that the product does not contain restricted substances above the set limits or affix a warning label informing consumers of potentially harmful substance contents.

This guide lists examples of product categories covered by California Proposition 65 and examples of restricted substances that may be present in such products.

Methodology

This guide is primarily based on products that are mentioned on www.p65warnings.ca.gov. The website contains:

a. Fact sheets covering specific product categories (e.g., “motor vehicle parts”), or;

b. Fact sheets covering specific substances (e.g., lead and lead compounds), which, in turn, provide examples of products that may contain restricted substances (e.g., ceramic dishes)

Note that these are not necessarily all products covered by California Proposition 65. Our understanding is that there is no definitive product list. Instead, California Proposition 65 is concerned with substances, rather than specific products. That being said, this guide can still help you form a clear understanding of which products are subject to California Proposition 65 and their respective substance risks.

How do I know if a product is covered by California Proposition 65?

California Proposition 65 is primarily concerned with restricting chemicals rather than listing specific products. As such, products are covered to the extent that they may contain substances restricted under California Proposition 65. This, in turn, depends on the materials.

Our recommendation is that you work with a qualified testing company to determine if:

a. Your products and materials are likely to contain substances restricted by California Proposition 65

b. If yes, determine which substances to test for

Food Contact Materials

The OEHHA lists several substances that may be present in food contact materials. Here are some of those substances, which could potentially cause harm to consumers:

• Lead and lead compounds
• Phthalates
• Bisphenol A (BPA)

Examples

Here are several food contact materials that may contain lead and lead compounds:

• Ceramic dishes
• Pewters
• Brass faucets and fittings

The California Proposition 65 website lists several consumer food contact materials that may contain phthalates:

• Plastic lunchboxes
• Plastic food packaging materials

BPA may be found in several consumer food contact materials, such as:

• Jar lids
• Baby bottles
• Sippy cups

It may also be found in other products, such as pacifiers.

Apparel and Textiles

Some chemical substances restricted under California Proposition 65 (e.g., flame retardants or formaldehyde) can be found in apparel and textile products. Flame retardants (e.g. PFOA) are often used in textile products to lessen the chances of them catching fire.

Formaldehyde is a gas that may be released into the air from various sources, such as permanent press fabrics. It is often used during the manufacturing of textiles and their accessories.

Examples

Products that may contain flame retardants, formaldehyde, or other restricted substances include:

• Textiles
• Outdoor gear
• Carpets
• Rugs
• Camping tents
• Linens
• Upholstery
• Draperies

Jewelry and Accessories

California Proposition 65 regulates the amount of heavy metals and other substances contained in jewelry. One of the most notable chemical elements that are used during the manufacturing process of jewelry is cadmium, which is often added to jewelry to impart specific technical and functional attributes to the metals.

Cadmium is commonly found in zinc ore, which increases the likelihood of low-cost zinc alloy jewelry being non-compliant with California Proposition 65.

Other than cadmium, the following toxic heavy metals are often found in the making of jewelry, which is restricted by California Proposition 65:

• Lead
• Antimony
• Chromium

Examples

Cadmium is often used in jewelry to provide a shiny aspect to the coating and weight to products such as:

• Zinc alloy jewelry
• Other metal jewelry
• Charms on children’s jewelry

Lead is a substance used in many jewelry products to increase their weight and brightness, or soften plastic parts. This includes:

• Imitation leather (which may include leather jewelry)
• Costume jewelry

Watches

The California Proposition 65 website does not explicitly list watches, to our knowledge. However, it is important to note that Proposition 65 does cover many materials and substances, such as lead and phthalates, that may be used to manufacture watch components such as the watch case or strap.

Examples

Here are some examples of products that contain materials that may include substances restricted by California Proposition 65:

• Watches with leather straps
• Watches with plastic straps

Toys

Toxic chemicals, such as flame retardant chemicals and phthalates, could sometimes be found in the coatings of plastic toys. Such substances are restricted by California Proposition 65 in the use of consumer products, including toys.

Other than toys that are made of plastic, toys that contain materials such as plush, fabric, wood, or ceramic could contain restricted toxic substances under the regulation of California Proposition 65.

Further, DEHP and other phthalates can sometimes be found in coatings applied to toy materials or laminations. As such, the base material used to make toys is not the only concern.

Examples

Toys that may contain the abovementioned chemicals and substances include items such as the following:

• Teddy bears
• Wooden toy cars
• Pretend tea sets
• Rubber ducks
• Toy surface coatings
• Toy paints
• Laminations

Other children’s products

Other children’s products (not toys) can contain substances on the California Proposition 65 list, such as antimony trioxide, TDCPP, and many more. For example, childcare products may contain the following phthalates:

a. DIDP

• Restricted to 0.1%
• Maximum Allowable Dose Level (MADL) of 2200 µg/day

b. DINP

• Restricted to 0.1%
• No Significant Risk Level (NSRL) of 146 µg/day.

Examples

Children’s products that may contain restricted substances and chemicals include items such as:

• Strollers
• Booster seats
• Bassinets
• Infant carriers
• Playpens
• Children’s books
• Pacififers
• Baby bottles

Furniture

Newly purchased furniture may release emissions that contain harmful chemical substances such as formaldehyde, benzene, and other volatile organic gases. Fire retardants are also very commonly detected in various kinds of sofas and other types of furniture, which can cause health issues such as liver cancer, kidney cancer, and reproductive and developmental issues to the users.

Examples

Furniture products may contain chemicals regulated by California Proposition 65. Examples of furniture materials that could contain these chemicals include:

• Textiles
• Vinyl textiles on cushions and upholstery

Formaldehyde, for example, can be found in resins used to make adhesives for composite wood products for furniture. This includes:

• Particleboard
• Fiberboard
• Plywood

Electronics

Toxic chemical substances and heavy metals that can be found within electronic products (or their casing) and are restricted include lead, PBDE, and cadmium.

Examples

PBDE is a flame retardant that may be found in the plastics used with electronic and electrical devices, such as personal computers.

Cadmium and its compounds can be found in many electrical products, such as rechargeable nickel-cadmium (NiCad) batteries. Products that use NiCad batteries include items such as the following:

• Cameras
• Cell phones
• Electric cars

Household appliances

The usage of household appliances may result in the emission of substances such as benzene, carbon monoxide, or formaldehyde. Also, the plastic components of household appliances may even contain various types of phthalates and flame retardants. California Proposition 65 restricts the use of those substances.

Examples

Here are some examples of household appliances that may contain or emit the substances listed on the California Proposition 65 List:

• Ranges
• Dryers
• Hot water heaters

Footwear

California Proposition 65 restricts various listed substances and chemicals, including chloroprene, BBP, and DEHP, which may be found in footwear products.

Examples

Footwear products that may contain chemicals and substances listed on the California Proposition 65 List include, but are not limited to:

• Shoes
• Leather footwear
• Rainwear

E-cigarettes

E-cigarettes discharge a vapor that typically contains nicotine. California Proposition 65 covers nicotine because it may cause birth defects or some form of reproductive harm. Some e-cigarettes also emit other substances such as lead and cadmium, which are also covered by the proposition.

Additionally, e-cigarettes are electronic devices as they use batteries to either:

a. Heat an e-liquid (a liquid solution inside the device), or

b. Heat solid substances (e.g., nicotine salts)

The components of e-cigarettes may also contain chemicals and substances restricted by California Proposition 65, such as phthalates.

Examples

Examples of e-cigarettes include items such as the following:

• E-cigars
• E-pipes
• E-hookahs
• Vape pens

Cosmetic Products

Cosmetic products often contain heavy metals such as lead and other dangerous substances.

These substances can cause harm to the skin, brain, and nervous system, and even cancer. As such, they are under the purview of California Proposition 65.

Examples

Lead can be found in cosmetics, such as the following:

• Kohl
• Surma
• Hair dyes

Personal Care Products

Personal care products may also contain chemicals and substances featured on the California Proposition 65 List, such as benzophenone, cocamide DEA, DBP, and 1,4-dioxane.

Examples

Here are some examples of personal care products that may contain substances listed on the California Proposition 65 List:

• Shampoo
• Conditioner
• Bath oil
• Body wash

Medical Equipment

Medical equipment may also contain substances that are restricted by California Proposition 65.

For example, mercury can be found in dental amalgam fillings, which is a material used during a medical dental procedure. Mercury exposure can result in childhood behavioral problems.

California Proposition 65 also restricts the use of different types of phthalates in medical devices because they can cause reproductive harm:

• BBP
• DBP
• DEHP
• DIDP
• DINP
• DnHP

Examples

Here we list some examples of medical equipment that may contain chemicals or substances covered by California Proposition 65:

• Surgical gloves
• Oxygen masks
• Feeding tubes
• Tubing for dialysis
• Some types of blood and IV bags

Gym Equipment

California Proposition 65 restricts many substances and chemicals, such as chlorinated tris and other flame retardants, which may be contained in gym equipment components such as textiles, plastics, and polyurethane foam.

Examples

Flame retardants such as chlorinated tris and other restricted substances may be found in items such as gym equipment that contains foam.

Motor Vehicle Parts

Components of, and used in, motor vehicles may have substances and chemicals that are restricted by California Proposition 65, such as automobile upholstery.

For example, motor vehicle parts may contain chemicals and substances such as DEHP, lead and lead compounds, and phthalates.

Examples

Here are some examples of products that may contain one or more of the above-mentioned substances:

• Lead-acid batteries
• Floor mats
• Seat covers
• Brake pads

Building Materials

Building materials may often contain chemicals and substances such as formaldehyde, styrene, and flame retardants, among other chemicals, which are restricted by California Proposition 65.

Examples

Building materials that may contain various chemicals and substances include items such as:

• Building insulation
• Plumbing pipes
• Insulated panels
• Rubber flooring
• Foam and fiberglass insulation

Food

A wide range of food products may contain chemicals and substances that are regulated by California Proposition 65. For instance, food may contain substances such as the following:

• Acrylamide
• Inorganic Arsenic
• Mercury
• Cadmium

Collectively, the chemicals and substances listed above may cause cancer, reproductive harm, birth defects, brain development issues, and behavior problems.

Examples

Food and food products that may contain various chemicals and substances restricted by California Proposition 65 include items such as the following:

• Rice
• Herbal medicines
• Edible seaweed
• Leafy vegetables
• Dietary supplements
• Fish

Additional Resources

a. California Proposition 65 Guide for US Importers & Amazon Sellers

b. List of California Proposition 65 Product Testing Companies

c. California Proposition 65 Product Lab Testing: A Complete Guide