Settlements Lead to Reformulation of Chemicals in Consumer Products Under California Prop 65

Geneva (July 29, 2025) – SGS, the world’s leading testing, inspection and certification company, has issued SafeGuardS 104.25 to inform stakeholders of multiple recent settlements under California Proposition 65 (Prop 65) involving the reformulation of chemicals in a wide range of consumer products.

Prop 65, officially known as the ‘Safe Drinking Water and Toxic Enforcement Act of 1986’, requires businesses to provide clear and reasonable warnings before exposing individuals in California to chemicals known to cause cancer, birth defects or other reproductive harm. The law currently identifies approximately 900 substances, with the list updated annually.

Recent settlements have addressed products containing several listed substances, including bisphenol A (BPA), lead, phthalates, chromium (VI) compounds, perfluorooctanoic acid (PFOA), diethanolamine (DEA) and 1,4-dioxane. In many cases, reformulation terms require the reduction or elimination of these substances to levels that avoid triggering warning requirements. Notably, certain settlements related to lead only restrict releasable lead, based on testing methods such as the NIOSH 9100 ghost wipe test.

These settlements are legally binding only to the named parties but provide important insight into evolving enforcement expectations. Businesses selling into the California market should review their compliance practices, especially concerning materials, labeling and chemical testing.

Additionally, stakeholders should prepare for upcoming regulatory changes, including the January 2028 requirement for short-form warning labels to identify at least one listed chemical, as outlined in SafeGuardS 177.24.

SGS publishes SafeGuardS to help industry stakeholders stay informed about regulatory and compliance developments. SafeGuardS 104.25 highlights recent Prop 65 settlements involving reformulations across multiple product categories and chemicals.

Stakeholders are advised to review SafeGuardS 104.25 to stay up to date with evolving Prop 65 requirements and ensure appropriate measures are in place to mitigate enforcement risks.

SGS Chemical Testing
SGS offers a comprehensive range of testing services to help manufacturers and suppliers ensure their products are safe and comply with national and international regulations concerning harmful chemicals. In the end, it’s only trusted because it’s tested. Learn more about SGS chemical testing services.

SGS SafeGuardS keep you up to date with the latest news and developments in the consumer goods industry. Read the full California Proposition 65: Reformulation of Chemicals in Consumer Products SafeGuardS.

Subscribe today and receive SGS SafeGuardS direct to your inbox.

For further information contact:

Dr. Hingwo Tsang
Global Information and Innovation Manager
Tel: +852 2774 7420

Melanie Tamayo
Senior Technical Manager, SGS NA
Tel: +1 312 414 9394

Website: www.sgs.com/cp
LinkedIn: SGS Connectivity & Products

About SGS
SGS is the world’s leading Testing, Inspection and Certification company. We operate a network of over 2,500 laboratories and business facilities across 115 countries, supported by a team of 99,500 dedicated professionals. With over 145 years of service excellence, we combine the precision and accuracy that define Swiss companies to help organizations achieve the highest standards of quality, compliance and sustainability.

Our brand promise – when you need to be sure – underscores our commitment to trust, integrity and reliability, enabling businesses to thrive with confidence. We proudly deliver our expert services through the SGS name and trusted specialized brands, including Brightsight, Bluesign, Maine Pointe and Nutrasource.

SGS is publicly traded on the SIX Swiss Exchange under the ticker symbol SGSN (ISIN CH1256740924, Reuters SGSN.S, Bloomberg SGSN:SW).

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