California Proposition 65 Compliance Checklist for Importers and Resellers

Use this checklist before you ship or list any product for sale in California, or whenever a supplier changes materials or components on an existing product.

1. **Identify listed chemicals in your product** — Check whether your product contains substances covered by California Proposition 65, such as lead, cadmium, inorganic arsenic, BPA, formaldehyde, or DEHP.

2. **Get a chemical exposure assessment** — Have your product or its components tested to estimate daily exposure levels for each listed chemical present.

3. **Compare results against exposure thresholds** — Lead has a No Significant Risk Level (NSRL) of 0.5 μg/day, cadmium 4.1 μg/day, inorganic arsenic 0.00001 μg/day (cancer MADL), BPA 3.0 μg/day, and DEHP 5.5 μg/day. Formaldehyde has no numeric limit but is a known carcinogen requiring a warning regardless of quantity.

4. **Collect chemical testing reports** — Keep documentation from a lab or supplier showing the actual levels found, not just a general statement of compliance.

5. **Determine if a warning is required** — If exposure is above the relevant NSRL or MADL, or the chemical is formaldehyde, you need a Clear and Reasonable Warning under California Proposition 65 requirements.

6. **Use approved Safe Harbor Warning text** — Warnings must follow the specific wording set out for the chemical category involved; generic warning language is not sufficient on its own.

7. **Place the warning where buyers will see it** — This means on the product label, packaging, or point-of-sale listing, depending on how the product is sold.

8. **Request supplier documentation upfront** — Ask suppliers for exposure assessments and test reports before you commit to an order, rather than after goods arrive in the US.

9. **Re-check after any formulation or material change** — A change in coating, plastic, pigment, or component supplier can change chemical content, so retest rather than assume the product is still compliant.

10. **Keep records on file** — Retain exposure assessments, test reports, and warning text used, in case a retailer, marketplace, or regulator asks for evidence of California Proposition 65 compliance.

This checklist covers the basics, but chemical exposure assessments and warning requirements can get detailed depending on your product category. You can read more on our [California Proposition 65](/regulations/california-prop-65) page, and see how [supplier compliance](/supplier-compliance) documentation is tracked, or try Complyra to see how it fits into your own workflow.