California Proposition 65 (1986) - Reformulation of Consumer Goods

Reformulation of Consumer Goods

Over the years, Prop 65 has led to consent agreements for a variety of consumer products, such as bibs, bicycles, products containing brass, cookware, cosmetics, exercise mats, ceramic ware and glassware, clothing, fake leather upholstery, headphone cables, jewelry, lunchboxes, poker chips, luggage, accessories and similar products.

In early 2011, a number of new Prop 65 consent agreements were reported, covering vinyl inflatable structures, vinyl lounge chairs, inspection lights with clamp handles, brass door handles, cadmium in jewelry and a revised judgment for fashion accessories.

In the latter part of 2011, further consent agreements were reported. These included reformulation of up to 1000 ppm DEHP for book covers and jackets. Further reformulations for lead content also concluded. For fashion jackets and belts with components that can be handled, touched or mouthed, two tests are necessary for compliance: less than 1.0 µg lead using method NIOSH 9100 and less than 100 ppm lead using EPA 3050B.

More recently, since December 2011 and during the first half of 2012, a further number of consent settlements for Prop 65 have been concluded, enforcing reformulation of a range of additional products by specifying the limits of heavy metals and organic chemicals.

Summary of the most recent settlements

In externally decorated glassware the cadmium and lead content are limited, with lower concentrations permitted for the lip or rim region. Lead content is also restricted in ceramic ware with exterior decorations, booster cables, and safety pins in varying concentrations. In the case of safety pins the preliminary limit is 300 ppm for 2012, but a much lower limit of 100 ppm will come into force in 2013. For the grips of hand tools the content of lead and certain phthalates are restricted. Various specific phthalates are also restricted in varying concentrations in notepads with vinyl coverings, purses, slippers, flip flops with rhinestones and similar plastic footwear, ear buds and headsets, and exercise/fitness mats. Restriction on volatile organic compounds (VOCs) is defined for smoothing solution products, and in this case a specific warning is mandatory in the material safety data sheets if the product releases detectable amounts of formaldehyde.