Jewelry Accessories California 65 Testing Process
Date：2026-02-27 09:44:44 Classification
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The export of jewelry and accessories to California, USA, and the California Proposition 65 testing is a key step in ensuring compliance and avoiding legal action. Due to the fact that jewelry products often contain materials such as metals, coatings, plastics, or gemstones, the key testing items are usually lead and cadmium, sometimes involving phthalates.
The following is the detailed process for applying for California 65 testing for jewelry accessories:
Step 1: Confirm product information and testing plan
Before formal application, it is necessary to clarify the specific material composition of the product, as different materials have different testing standards and limit requirements.
Material identification: Disassemble the product and distinguish between metal substrates (such as alloys, stainless steel, silver), surface coatings (paint, electroplating), plastic/resin components, leather/textile ropes, etc.
Determine the testing items:
Metal components: mainly measure lead and cadmium. This is the most essential testing item for jewelry.
Plastic/coated components: testing for lead, cadmium, and phthalates (such as DEHP, DBP, etc.).
Gemstone/imitation gemstone: measure the leaching amount of lead and cadmium.
Confirmation limit: California 65 itself is a "labeling law" and there is no unified mandatory limit. However, in practical operation, laboratories usually refer to the limit values in previous settlement agreement cases (for example, lead content is usually required to be below 100 ppm or 300 ppm, cadmium content is below 300 ppm, etc., depending on the material and purpose).
Step 2: Fill out the application form
Submit an application to the testing agency (third-party laboratory, Dezewei Testing CNAS registration number: L8083):
Fill out the testing application form.
Provide basic product information: name, model, material list (BOM).
Clearly state the language of the report (usually in English, used for viewing by US clients or customs).
Step 3: Sample Preparation and Inspection
Prepare samples according to laboratory requirements:
Sample quantity: Usually 2-3 finished products are required. If the product has multiple colors or significant differences in material, separate samples may be required.
Splitting requirements: If the laboratory is not responsible for splitting, the applicant must package the components of different materials separately and label them clearly, so that the laboratory can conduct independent testing for different materials.
Step 4: Laboratory Testing
After receiving the samples, the laboratory conducts chemical analysis according to standard procedures:
1. Sample pretreatment: Crush or cut metal parts, and scrape off coatings.
2. Chemical testing:
Lead testing: Typically, EPA 3050B/3051A or CPSC-CH-E1001-08 standard methods are used to detect total lead content using ICP-OES (inductively coupled plasma emission spectrometer) or AAS (atomic absorption spectrometer).
Cadmium testing: Use a similar method to detect the total cadmium content. For certain specific materials (such as imitation crystals), dissolution testing (simulating the amount of precipitation in stomach acid environment) may be required.
Phthalate testing: For plastics and coatings, GC-MS (gas chromatography-mass spectrometry) is used for detection.
Step 5: Issue a report
After the testing is completed, the laboratory analyzes the data:
Qualified: If the values of all test items are below the limits of the settlement agreement or safe harbor standards, the laboratory will issue a qualified test report. Enterprises can use this report to prove product compliance, and usually do not need to attach warning labels.
Unqualified: If the value exceeds the standard, the laboratory will issue an unqualified report. At this point, the enterprise needs to:
1. Improve the process or replace raw materials.
Alternatively, a warning label in accordance with Prop 65 can be affixed to the product packaging to inform consumers that the product contains specific chemicals.
Step 6: Report usage and subsequent maintenance
Purpose of the report: The test report is mainly used to demonstrate product compliance to California retailers and importers, respond to market inspections, and serve as evidence to avoid potential litigation.
Validity period: The California 65 test report does not have a fixed validity period. As long as the product material and production process remain unchanged, and regulations are not updated, the report is valid for a long time.
Summary: Key Points of California 65 Testing for Jewelry and Accessories
1. Core project: Lead and cadmium are mandatory testing items.
2. Reference basis: Mainly referring to the settlement agreement limits for the jewelry industry in the past.
3. Final objective: Determine whether to "exempt warning labels" or "must add warning labels" based on test data.
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