Test report for California Proposition 65 certification of electronic products
Date：2026-02-06 10:00:13 Classification
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Meeting California Proposition 65 regulations can help avoid lawsuits after products are launched in the US market, thus increasing their chances of success.
Specific Requirements and Decision-Making Processes for Electronic Products
The California Proposition 65 risks for electronic products primarily stem from chemicals in their various material components.
1. High-Risk Chemicals and Common Sources
Electronic products require close monitoring of the following substances and their sources:
Chemicals Common Sources (in electronic products)
Lead: Solder joints, alloys, glass, PVC cable sheaths, certain pigments and coatings.
Cadmium: Electroplating layers, certain switch and battery contacts, older plastic stabilizers.
Phytaldehyde (e.g., DEHP, BBP, DBP): Flexible PVC components (e.g., cable sheaths, grips, connector sleeves), rubber components.
Flame Retardants (e.g., TDCPP, TCEP): Plastic casings, circuit boards, insulating materials.
Bisphenol A: Polycarbonate plastic casings, epoxy coatings.
2. Core Compliance Path: How to Obtain Test Reports
Your goal is not to test all of nearly a thousand substances, but to conduct risk-based, targeted testing.
Step 1: Product Screening and Risk Assessment
Review the Bill of Materials (BOM): Identify all plastic, rubber, coating, metal, and glass components.
Require Supplier Declarations: Mandatory requirement for all suppliers to provide written declarations of conformity for their materials according to California Proposition 65, along with supporting test reports.
Identify High-Risk Components: Focus on accessible soft PVC components, coated plastic/metal casings, welded joints, cables, etc.
Step 2: Engage a Professional Third-Party Tester
Select a Laboratory: A qualified and widely recognized third-party laboratory must be selected (DEZEW Testing CNAS Registration No.: L8083).
Determine the Testing Plan: Communicate with the laboratory to determine the testing items and methods based on the product risk assessment. Common testing standards: CPSC-CH-C1001-09.3 (total lead and cadmium testing), EPA testing methods (for phthalate migration or total phthalate levels). Test Types: Surface Wipe Test: Simulates skin contact to test for migratable lead and cadmium content. Crucial for accessible parts. Leaching/Migration Test: Simulates saliva or sweat contact to test for the amount of chemicals leached out. Total Chemical Content Test: Directly tests the total content of a specific chemical in the material.
Step 3: Decision Based on Report Results
Results "Not Detected" or Below "Safe Harbor": Preserve the complete chain of evidence: including your internal assessment records, supplier conformity statements, and your own third-party testing reports. No warnings are required. This documentation is your "shield" against regulatory or litigation issues.
Results Above "Safe Harbor": Option A (Preferred): Redesign or replace the materials to address the problem at its source. Option B: Affix a clear California 65 warning label to the product (⚠ Warning: This product contains chemicals known in California to be carcinogenic and/or reproductively toxic). This is legal and compliant but may affect sales.
When inquiring with clients or regulatory bodies, you should be able to provide a complete package of compliance evidence, not just test data. This typically includes:
1. A California Proposition 65 compliance assessment report: outlining your risk assessment process, testing protocols, and conclusions.
2. Key third-party testing reports: Original test reports for high-risk substances and accessible components.
3. Supply chain conformity declarations: Conformity declarations and supporting data from all key component suppliers.
4. Technical documentation: Product bill of materials, high-risk component identification diagrams, etc.
5. Declaration of conformity: A formal declaration issued by the company guaranteeing that the product complies with California Proposition 65 requirements (based on existing assessments and testing).
Important Reminder
"Accessible" is key: Regulations focus on parts that consumers may come into contact with during normal use. The risk of internal chips is generally lower than that of the casing or cables.
Extremely high litigation risk: California Proposition 65 is a "private litigation" law, where plaintiffs' lawyers can receive a share of the substantial settlement. Proactive testing and evidence preservation are the only ways to protect yourself.
Conclusion:
For exporting electronic products to California, the most professional approach is to immediately conduct third-party testing on all accessible components (especially flexible PVC, coatings, and casings) for high-risk substances such as lead, cadmium, and phthalates, and establish a complete supply chain compliance documentation system. Only in this way can you confidently present "California 65 compliance test reports and supporting documentation" when questioned, effectively mitigating legal and commercial risks.
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