In principle, personal behavior is not regulated. C2C (customer to consumer) is not regulated, but B2B and B2C are regulated.

E.g. DEHP, BPA, Pb are NOT acceptable. You must use the exact wording as listed in the official list (The Proposition List). For example:

• DEHP official name: Di(2-ethylhexyl)phthalate (DEHP)
• BPA official name: Bisphenol A (BPA)
• Pb official name: Lead

• If multiple chemicals only cause cancer, listing just one (or more) is sufficient.
• If multiple chemicals only cause reproductive toxicity, listing just one (or more) is sufficient.
• If some chemicals cause cancer and others cause reproductive toxicity, list at least one (or more) for cancer and one (or more) for reproductive toxicity.

Such packaging is usually discarded immediately, so it is less likely to be targeted by specific individuals (e.g. bounty hunters or environmental lawyers). Therefore, the risk under Proposition 65 is relatively low (but not zero). California is also a member state of TPCH (also known as the U.S. Packaging Directive), so your company must also comply with those requirements.

Yes. Although consumers may not normally touch the product after installation, making lawsuits less likely, installers may still be exposed. Even if installation takes only 3–5 minutes per unit, a worker may install dozens per day and thousands per year. Long-term exposure to toxic substances could still lead to claims. Recycling workers may also be exposed during disassembly and could file claims.

Proposition 65 applies to the entire supply chain within California, including assembly workers, transport workers, installers, operators, and recycling workers. If non-government personnel are involved, compliance is still required.

SGS provides services in two stages: (1) testing content levels, and (2) working with U.S. toxicologists to determine exposure levels. Warning label recommendations are then provided based on these results.