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California, USA 65

2023-11-06

California proposal 65   testing service


What is California 65 ?

California Proposition 65 , referred to as California 65 , commonly known in English as Cal65 , CP65 or Prop65 , the full name is the " Drinking Water Safety and Toxic Substances Enforcement Act of 1986". This act was issued in November 1986. Its purpose is to protect California residents and The state's drinking water sources must be free of substances known to cause cancer, birth defects or other reproductive and developmental harm, and truthfully notify residents when such substances are present. California Proposition 65 regulates chemicals known to the state to cause cancer or reproductive toxicity. Currently, more than 700 chemicals are classified as such chemicals and subject to supervision.


California 65 Testing / Testing

Nowadays, the California 65 test involves almost all daily necessities and related materials and packaging. The scope of application is not limited to the California area but is more of a requirement imposed by importers on products entering the US market.

There are many hazardous substances controlled by California 65 and the requirements are updated every year. The testing requirements for different types of products and materials are generally different. The specific testing items need to be determined based on the harmful ingredients that may be involved in the product materials and combined with the customer's requirements.

At present, the common test items in California 65 mainly include:

Lead ( Pb ) general limit 100ppm  

Cadmium ( Cd ) general limit is 300ppm   

Phthalate  (DBP , BBP , DEHP , DIDP , DnHP , DINP)  general limit 1000ppm/ kind

FormaldehydeFormaldehyde general  limit  75ppm 

Bisphenol A   general limit  is 1000ppm

Flame retardant testing common flame retardant testing items are as follows, the general limit is 25ppm/ kind

Trimethyl  PhosphateTMP  512-56-1

Triethyl Phosphate  TEP  78-40-0 

Tributyl  PhosphateTBP  126-73-8 

 Tris (  2 - chloroethyl Phosphate TCEP115-96-8

Tris(1,3-  dichloro - 2  -  propyl ) Phosphate TDCP (  TDCPP ) 13674-87-8

Triphenyl  PhosphateTPP  115-86-6 

Tris( 2 - butoxyethyl Phosphate  TBEP  78-51-3

Tris ( 2 -ethylhexyl  ) Phosphate TEHP  78-42-2 

Tris-o-cresyl  PhosphateTOCP  78-30-8 

Tris-m-cresyl  Phosphate  TMCP  563-04-2 

Tris-p-cresyl Phosphate  TPCP  78-32-0 

Tris ( 2 -chloropropyl  ) phosphate TCPP  13674-84-5 

Tetrabromobenzoate, 2- ethylhexyl  -2,3,4,5-tetrabromobenzoate  TBB   183658-27-7 

Bis(2 - ethylhexyl) -tetrabromophthalate , Bis(2-Ethylhexyl)-3,4,5,6-tetrabromophthalate  

Diisooctyl tetrabromophthalate  TBPH 26040-51-7


California 65 Chemical List Update

The California 65 List is revised and republished at least once a year. New substances are usually added to the list, and the limits of original substances are also adjusted. For example, the requirements for glassware and ceramics in California Document No. 65 were promulgated in 1986 . The Safe Drinking Water and Toxic Enforcement Act, known as Title 65 , requires a warning on any product in California that emits chemicals that cause cancer or reproductive toxicity. Among the chemicals listed are lead and cadmium.

Glass-ceramic products that meet the standard requirements can be sold in California without the warnings required by File 65 .

For products that cannot meet the remanufacturing standards, the warnings required by Document No. 65 must be marked on the product.

Listed below are consensus guidelines for warning labels on glassware and ceramics.

For exterior decoration of glassware, including rim areas, only decorative materials containing less than 0.06% lead and  0.48% cadmium may be used .

All exterior decoration extending to the edge area may only use decorative materials with no detectable lead or cadmium ( ≤ 0.02% lead , ≤ 0.08% cadmium).


California 65 Regulation Updates

In October 2017, five  new toxic and hazardous substances were added to the California 65 list:

The California Office of Environmental Health Hazard Assessment (OEHHA)  announced that five new chemicals have been added to the toxic and hazardous list of California’s Proposition 65 , among which perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate ( PFOS) are classified as developmental toxic. The other three chemicals are: N,N- dimethylformamide , dimercaptobenzothiazole and tetrabromobisphenol A , which are classified as carcinogenic. 

In August 2016, California 65 revised the regulations and requirements for warning signs:

On August 30 , 2016 , the California Office of Environmental Monitoring and Hazard Assessment approved the amendment to Clause 6 of California’s Proposition 65, Clear and Reasonable Warning Messages.”

This amendment repeals Section 6 of Title 27 of California Bill 65 and replaces it with two new subsections.

The amendment stipulates that an equilateral triangle graphic with a black exclamation mark must be displayed on the left side of " WARNING ", and the name of at least one hazardous substance should be reflected in the warning content. On-product warnings are also given . The amendment also provides detailed regulations on the font size and posting method of warnings for different consumer products, and also stipulates that consumers must be directed to the official California 65 website. At the same time, the amendment also details the relevant responsibilities of manufacturers and retailers.

California’s 65 pairs of bisphenol A requirements updated in May 2016 :

Beginning on May 11 , 2016 , California’s Safe Drinking Water Toxic Substances Regulations , also known as California Proposition 65 , stipulate that companies with 10 or more employees must produce, distribute, or sell products containing bisphenol A ( BPA) . ) products, if the content of bisphenol A exceeds the safety warning value, clear and correct warnings need to be marked on the product.

On March 17 , 2016 , the Office of Environmental Health Hazard Assessment ( OEHHA ) proposed the introduction of a California 65 emergency regulation that requires any canned and bottled food and beverages to provide clear and correct warnings if they contain bisphenol A.

The content of the warning should be as follows:

WARNING: Many of the metal cans sold here for food and beverages contain epoxy linings, which are used to prevent microbial contamination and extend shelf life. Lids on jars and caps on bottles may also contain epoxy linings. Some of these epoxy resin liners can leach small amounts of bisphenol A ( BPA ) into food or beverages.

In California, bisphenol A is a well-known chemical that can harm the female reproductive system.

California 65 warning label revision requirements in January 2015 : 

The California Office of Environmental Health Hazard Assessment ( OEHHA ) is proposing revisions to the warning label requirements in California’s Proposition 65 . Previously, California’s Proposition 65 stipulated that all products containing substances defined by California as carcinogenic or reproductively toxic were required to add warning labels. The proposal requires warning labels to provide more relevant information to the public.

In addition, OEHHA also proposes to establish a dedicated website to provide the public with more "supplemental information" related to chemicals on the California Proposition 65 list.

This amendment to California 's Proposition 65 requires responsible persons to add warning labels to products that "knowingly or intend to expose people to chemicals on the California Proposition 65 list." Next to the word "Warning", add an icon with a black exclamation mark inside a yellow triangle. In addition, if a product requires a warning label and contains the following chemicals, the names of these chemicals must be listed on the warning label: acrylamide, arsenic, benzene, cadmium, carbon monoxide, tris( 1,3- dichloroisopropyl) base) phosphate, formaldehyde, hexavalent chromium, lead, mercury, methylene chloride, phthalates

In June 2015, California 65 included ethylene glycol in the control list:

The California Office of Environmental Health Hazard Assessment ( OEHHA ) has included ethylene glycol ( CAS No. 107-21-1 ) in the substance list of California Proposition 65 (" Drinking Water Safety and Toxic Substances Enforcement Act of 1986 "). Because it can cause reproductive toxicity through absorption, this decision came into effect on June 19 , 2015 .

According to the relevant requirements of California 65 , all products containing ethylene glycol sold in California need to have warning labels. No substances on the list may be released into drinking water sources.

Companies have one year from the effective date to remove ethylene glycol from their products or add warning labels to their products.

Ethylene glycol is commonly used in the production of polyester compounds, mainly in polyethylene terephthalate ( PET ) and polyester fibers and films. It can also be used in surface coatings, antifreeze, deicing fluids, In surfactants and emulsifiers.

In December 2014, California 65 included DINP in the control list:

Starting from December 20 , 2014 , all exported products within the control scope of California’s Proposition 65 must comply with the relevant provisions of phthalates in the Act. Diisononyl phthalate ( DINP, Diisononyl phthalate, CAS) No.: 28553-12-0 ) for testing.

So far, there are no relevant court cases or out-of-court settlement cases that prove that the content of DINP has a safe range. Therefore, the current DINP testing report will not give a conclusion of passing or failing, but will write a warning note in the report. Used to remind customers.

The content of the warning notes is as follows:

“Diisononyl phthalate ( DINP ) has been detected in the sample, but its maximum safety limit is currently unclear. For chemicals that do not have safety limits set in California’s Proposition 65 , operations containing this chemical Companies that commercialize a substance must provide a California Prop 65 warning unless the company can demonstrate that expected levels of exposure to the product do not pose a significant risk of cancer or reproductive toxicity."

In March 2012, California 65 included methanol and trichlorethylene on the control list:

On March 16 , 2012 , the California Office of Environmental Health Hazard Assessment ( OEHHA) issued an announcement officially adding "Methanol (CAS No .: 67-56-1) " to the California 65 Toxic and Hazardous Chemicals list.

According to the official identification of the authoritative US National Toxicology Program (NTP) , methanol is included in the California 65 list. The NTP Human Reproduction Risk Assessment Center reports that methanol can cause reproductive toxicity  ( developmental endpoints ) . Criteria for the "authority" used by OEHHA to evaluate chemical substances for listing can be found in Section 27 of Chapter 25306 of the California Registration Code (Cal. Code of Regs.) .

In addition, OEHHA updated the no significant risk levels (NSRLs) for another substance, trichlorethylene , and solicited public comments.


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