Q: What is California 65?

A: California 65, the California State of California proposal to increase attention to accessible toxic chemicals, referred to as the "California 65 Proposal."

In November 1986, the State of California enacted the 1986 Drinking Water Safety and Toxic Substances Enforcement Act, which was later compiled into the California Health and Safety Code, Chapter 25249.5-25249.13.

Q: What are the requirements for California 65? How should the product meet the requirements of California 65?

A: California 65 currently controls nearly a thousand substances, and the substances in the list do not set limits. For enterprises, it is difficult to completely control such a large amount of material, and updating the control substances every quarter is also one of the difficulties in management and control.

It is recommended that enterprises find the limit requirements for such products in the existing lawsuits according to the product type, and investigate the content of their products to determine whether they meet the requirements for hazardous substances in the relevant lawsuits. If the restricted substance exceeds the limit of the relevant litigation case, the company should put a warning label on the product. At present, the California 65 related lawsuit involves many types of products in many fields such as electrical and electronic, toys, and food contact materials.

Q: If the product passes the phthalate test related to the California 65 Act, do you think that the product meets the requirements of the new four phthalates in RoHS?

A: I can't think so.

These two regulations differ in terms of control scope, control limits, control substances, and test methods. Therefore, it is necessary to separately test and judge whether the requirements are met.

Q: How is the current limit of the California 65 Act defined? Is there a limit? Where are these limits available on an authoritative basis? What is the limit on DINP? When will it take effect?

A: The California 65 bill came into effect in 1986. There are no clear limits in the bill. The limits are from litigation cases (consumers after the lawsuit against the company). There is no official website for litigation cases. If you have information needs, you can contact us directly to provide professional advice.

The limits for DINP vary depending on the product and the limits vary.

If you are interested in researching this regulation, it is recommended to know through the following official website:

Https://oehha.ca.gov/proposition-65

Q: There are more than 900 substances listed in the California Act 65, but many test institutions mostly use the substances and limits after the court decision. If the company's product contains antimony trioxide (CAS No. 1309-64-4) in the list, the ratio of addition is at least 10,000 ppm. In this case, does the product meet the requirements of California 65?

A: Most electronic companies are controlled by reference to California's 65 lawsuits. The substances and limits are controlled by lawsuits. Although there are no cases in which electronic products are prosecuted for exceeding the standard of antimony trioxide. But antimony trioxide is a carcinogen, and it is in the list of California 65, and does not rule out future consumer concerns.

From the perspective of risk, it is recommended that the company first investigate the use of the substance in each material through the supply chain survey, and the subsequent process gradually reduces or even bans the substance.

Q: If a company is a manufacturer or manufacturer of consumer goods, but does not sell directly to retailers, how should it meet the retail seller's requirements for providing warnings?

A: Companies that do not sell directly to retailers have two options that meet the requirements:

(1) Identify the product with the necessary warnings;

(2) Provide warning notices and warning materials to packers, importers, suppliers or distributors.

With the second option, companies should ensure that warning messages are delivered along the supply chain and ultimately reach consumers. Manufacturers or manufacturers can choose to contract with other companies in other business chains to ensure that their products are properly delivering warnings to retailers and end consumers.

Q: How do you determine if a California 65 list substance is carcinogenic or reproductively toxic or has both characteristics?

A: Companies can view or download the complete list of California 65 by visiting the following California 65 List official website. The “Toxicity Category” column of the list lists the toxicological properties of the relevant substances:

Https://oehha.ca.gov/proposition-65/proposition-65-list

Q: The California 65 proposal requires a standard format warning to reflect “one or more” hazardous substances. If the company determines that there are five California 65 listings that need to provide warnings, do all five of these substances need to be reflected in the warning?

A: If the five substances are carcinogens, the enterprise may only reflect the name of one of the five substances in the warning, or may choose to simultaneously display any one or all four of the other four substances;

If the five substances include both carcinogenic and reproductive toxicity substances, the company can only indicate the name of one of the carcinogens and one of the names of the substances that cause reproductive toxicity in the warning, and also choose to show more in the warning. Material name;

If a substance has both carcinogenic and reproductive toxicity characteristics, the warning only needs to reflect the name of the substance, and at the same time reflect the two characteristics of carcinogenicity and reproductive toxicity. The enterprise may also choose to embody more substance names.

Q: Can I use the abbreviation of the chemical substance name in the warning sign? For example, if a product needs to provide a warning sign for "diethylhexyl phthalate", can the abbreviation "DEHP" be used in the warning sign to replace the full name of the substance?

A: The name in the warning label needs to be the same as the name in the California 65 official list.

If the abbreviation is included in the warning symbol as part of the full name of the chemical substance, the abbreviation can be used separately in subsequent references.

Q: If the company cannot print in color, can the triangle warning symbol be printed in black and white?

A: If the company does not use yellow printing for other information on the label, the triangle warning symbol can be printed in black and white.