By PlasticAdditives.net Editorial Team. Every listing date on this page is checked against the OEHHA Proposition 65 list; see our methodology and fact-checking process. Proposition 65 list edition: 31 July 2026. Regulatory status verified: 22 September 2026. This page is a technical reference for formulators and compounders, not legal advice.
25 listing entries on California's Proposition 65 list catch a substance that is intentionally added to a plastic, from DEHP, listed for cancer on 1 January 1988, to glycidyl methacrylate, listed on 27 January 2023. Proposition 65 bans none of them, so what does a listing actually oblige a compounder to do?
Proposition 65, formally the Safe Drinking Water and Toxic Enforcement Act of 1986, obliges a business to give a clear and reasonable warning before it knowingly and intentionally exposes a person in California to a listed chemical, unless that exposure stays below the chemical's safe harbor level. The 25 listings that reach a plastic additive fall into 5 families, in the order this page follows throughout: plasticizers, flame retardants, heat stabilizers, colorants and fillers, and antioxidants, modifiers and antistatic additives.
This page maps all 25 listings against those 5 families of plastic additives, the safe harbor levels OEHHA has published, the polymers most likely to carry a warning, what a compliant warning contains, how a compounder screens a formulation in 7 steps, the declaration customers ask for, and how Proposition 65 differs from REACH, the CPSIA and FDA food-contact rules. Each entry is matched to the family of plastic additives it belongs to, so a formulator can find the listing that applies to a specific compound without reading the full OEHHA list.
Table T1: The 5 Proposition 65 additive families
| Additive family | Listings | Flagship listed substance | Endpoint | Typical host polymer or product |
|---|---|---|---|---|
| Plasticizers | 7 | DEHP | cancer, developmental, male reproductive | flexible PVC (5-65 wt% plasticizer) |
| Flame retardants | 8 | antimony trioxide | cancer | HIPS, ABS, PP, PBT, PA with a halogen donor |
| Heat stabilizers | 1 group entry | lead and lead compounds | cancer, developmental, female and male reproductive | legacy rigid PVC |
| Colorants and fillers | 6 | titanium dioxide | cancer (airborne, unbound, respirable particles only) | white masterbatch, all pigmented plastics |
| Antioxidants, modifiers and antistatic additives | 3 | glycidyl methacrylate | cancer | reactive impact modifiers and chain extenders |
A group entry such as "lead and lead compounds" catches every additive built on that metal, so one row covers lead stearate, tribasic and tetrabasic lead sulfate, dibasic lead phosphite and lead chromate pigments.
What Is California Proposition 65?#
California Proposition 65, formally the Safe Drinking Water and Toxic Enforcement Act of 1986, requires a business to give a clear and reasonable warning before it knowingly and intentionally exposes a person in California to a chemical on the Proposition 65 list. Which obligations does a listing therefore not create? A Proposition 65 listing sets no concentration limit in the finished article and imposes no import ban; the sole obligation is the warning itself. The list that carries the 25 additive-relevant entries is maintained by the California Office of Environmental Health Hazard Assessment (OEHHA) and republished at least once a year, with the edition in force on this page dated 31 July 2026.
Why Proposition 65 is a warning law and not a ban#
A Proposition 65 listing creates a duty to warn, not a restriction: DINP has been listed for cancer since 20 December 2013 and remains lawful to sell in California at any concentration, provided the exposure is warned or stays below its no significant risk level of 146 micrograms a day. The contrast with the European Union is direct. REACH Annex XVII entry 51 limits DEHP, DBP, BBP and DIBP to 0.1 % by weight of the plasticized material in every article placed on the EU market, in force since 7 July 2020, while Proposition 65 sets no equivalent concentration ceiling and triggers only a warning duty. A Proposition 65 listing also does not withdraw an existing FDA food-contact clearance; the two systems operate independently.
Who has to give the warning and who enforces it#
The warning duty falls on any business with 10 or more employees that causes the exposure, which in a plastics supply chain means the brand owner or the importer selling the finished article in California, not usually the additive supplier. Three parties sit inside the warning chain:
- The business with 10 or more employees that causes the exposure, typically the brand owner or importer of the finished plastic article
- The private enforcer, who files a 60-day notice against a suspected violation before any lawsuit proceeds
- The California Attorney General, who can also bring an enforcement action
In practice, private 60-day notices, not government inspections, are the exposure a compounder's customer actually faces. California is one layer of US state laws on plastic additives, and the fastest-moving one, which is why customers ask their compounders for a current Proposition 65 statement well before any other state disclosure.
Does Proposition 65 apply outside California?#
Proposition 65 applies only to exposures that happen in California, but a supplier that sells one labelled version of a part into all 50 states carries the warning everywhere, which is why Prop 65 labels appear far outside the state. The legal trigger stays tied to an exposure in California. Because most suppliers manufacture and label one stock-keeping unit for the whole United States rather than a California-specific version, the practical reach of the law extends nationwide as a matter of commercial practice, not as a matter of law.
25 Plastic Additives on the Proposition 65 List#
The 25 Proposition 65 listings that catch a plastic additive fall into 5 families: 7 in plasticizers, 8 in flame retardants, 1 group entry covering all lead heat stabilizers, 6 in colorants and fillers, and 3 across antioxidants, reactive modifiers and antistatic additives. The count treats an individual substance entry, such as DEHP (CAS 117-81-7), and a chemical group entry, such as "lead and lead compounds," each as one listing.
Plasticizers: 7 listings covering 6 phthalates and chlorinated paraffins#
7 of the 25 listings are plasticizers: the 6 ortho-phthalates DEHP, DINP, DIDP, DBP, BBP and DnHP, plus the chlorinated paraffin entry that catches short-chain grades. DEHP was listed for cancer on 1 January 1988 and for developmental and male reproductive toxicity on 24 October 2003. DINP was listed for cancer on 20 December 2013, with its no significant risk level of 146 µg/day revised on 1 April 2016. DIDP was listed for developmental toxicity on 20 April 2007, DBP for developmental, female and male reproductive toxicity on 2 December 2005, BBP for developmental toxicity on the same date, and DnHP for female and male reproductive toxicity on 2 December 2005. A seventh entry, chlorinated paraffins with an average chain length of C12 and approximately 60 percent chlorine by weight (CAS 108171-26-2), was listed for cancer on 1 July 1989; this is the entry that catches short-chain chlorinated paraffins.
Flexible PVC carries 5 to 65 wt% plasticizer, which is why the ortho-phthalate listings concentrate in this family. DINP is authorized at up to 43 wt% of vinyl chloride polymers in US food contact under 21 CFR 178.3740, and a 2018 study measuring PVC medical tubing found DINP levels of 34.9 to 48.7 wt%. The full dosage ranges and grade comparisons for every plasticizers for plastics grade sit on that hub page.
A 2024 analysis by Klotz found that DINP substitutes for DEHP at close to a 1:1 ratio in flexible flooring formulations, which is the clearest documented reformulation pathway inside this family. MCCP is not listed under its own name; only the C12 chlorinated paraffin entry above exists on the Proposition 65 list. DIBP and DCHP carry no Proposition 65 listing at all and are covered separately in the non-listed table below.
Flame retardants: 8 listings#
8 of the 25 listings are flame retardants, led by antimony trioxide, the bromine synergist listed for cancer on 1 October 1990 and present in almost every halogenated flame-retardant package. The remaining 7 entries are TDCPP, listed for cancer on 28 October 2011; TCEP, listed for cancer on 1 April 1992; TBBPA, listed for cancer on 27 October 2017 through the Labor Code listing mechanism; molybdenum trioxide, listed for cancer on 19 March 2021, also through the Labor Code mechanism; the pentabromodiphenyl ether mixture DE-71, listed for cancer on 7 July 2017; tris(2,3-dibromopropyl) phosphate, listed for cancer on 1 January 1988; and 2,2-bis(bromomethyl)-1,3-propanediol (CAS 3296-90-0), listed for cancer on 1 May 1996.
Antimony trioxide is always paired with a bromine or chlorine donor rather than used alone. A bromine-synergist datasheet reports that 5 wt% antimony trioxide with 10.7 wt% bromine reaches a UL 94 V-0 rating at 0.8 mm in HIPS, which explains why the two listings travel together in almost every halogenated formulation. TDCPP goes into flexible polyurethane foam for furniture, automotive seating and juvenile products; TCEP is used in polyurethane, polyester resins and polyacrylates; and TBBPA is reactive in FR-4 epoxy laminates and additive in ABS housings. Halogen-free routes to the same UL 94 rating are compared on flame retardants for plastics.
Antimony trioxide is not classified as an SVHC under REACH. TBBPA and molybdenum trioxide reached the Proposition 65 list through the Labor Code listing mechanism, the only listing mechanism this page names, because it is the only one confirmed in our source library for these two entries. Polybrominated biphenyls are also a legacy listed flame retardant, for cancer and developmental toxicity, but the listing date is not established here, so they are named without a date and excluded from the 25-entry count.
Heat stabilizers: lead and lead compounds#
One group entry, "lead and lead compounds," covers every lead-based PVC heat stabilizer at once: it has been listed for cancer since 1 October 1992, and lead itself for developmental, female and male reproductive toxicity since 27 February 1987. Because the entry is a chemical group rather than a named substance, it catches lead stearate and dibasic lead stearate, tribasic lead sulfate, tetrabasic lead sulfate, dibasic lead phosphite and lead chromate pigments without any of them appearing on the list individually.
Lead stabilizers are legacy chemistry: calcium-zinc and organotin systems have replaced them across most rigid PVC formulations, and the dosage ranges for both replacement classes and the remaining lead systems are compared on PVC heat stabilizers. The European route to the same substances is a hard concentration limit rather than a warning. REACH Annex XVII entry 63 restricts lead in PVC articles to below 0.1 % by weight from 29 November 2024, with recovered rigid PVC allowed up to 1.5 % lead until 28 May 2033, a derogation with no equivalent under Proposition 65 (see lead in PVC for the full REACH entry).
Colorants and fillers: 6 listings and the "airborne particles" qualifier#
6 of the 25 listings sit in colorants and fillers, and 3 of them, titanium dioxide, carbon black and crystalline silica, are listed only as airborne unbound particles of respirable size. The full entry wording is "titanium dioxide (airborne, unbound particles of respirable size)," listed for cancer on 2 September 2011, and "carbon black (airborne, unbound particles of respirable size)," listed for cancer on 21 February 2003. Silica, crystalline (respirable), was listed for cancer on 1 October 1988. The remaining 3 entries carry no airborne qualifier: cadmium and cadmium compounds, listed for cancer on 1 October 1987 and for developmental and male reproductive toxicity on 1 May 1997; chromium (hexavalent compounds), listed for cancer on 27 February 1987 and for developmental, male and female reproductive toxicity on 19 December 2008; and talc containing asbestiform fibers, listed for cancer on 1 April 1990.
HDPE PE100 pressure pipe carries 2 to 2.5 wt% carbon black under ISO 4427, typically let down from a 35 % masterbatch at 5 to 6.5 %, and the dosage ranges for every pigment class are compared on colorants for plastics. Asbestos-free talc carries no Proposition 65 listing; only talc containing asbestiform fibers does.
The titanium dioxide, carbon black and crystalline silica listings describe airborne unbound particles of respirable size, which is a powder-handling condition at the weighing and feeding station of a compounding line, not a property of the pigment once it is bound inside a finished plastic part. This page states that qualifier as it is worded by OEHHA and does not conclude that a finished, pigmented part is exempt from a warning, because no OEHHA guidance on that specific question exists in our source library. Titanium dioxide carries no harmonized EU hazard classification following the General Court's annulment of 23 November 2022, upheld on 1 August 2025, a contrast worth noting but not a claim that titanium dioxide is unclassified everywhere. Talc has a proposed classification only: the ECHA Risk Assessment Committee opinion of 20 September 2024 recommends Carc. 1B and STOT RE 1, but that opinion is not yet in CLP Annex VI, so this page writes it as proposed, never as classified. The loading levels for talc and silica fillers, the two entries this qualifier touches most directly, are compared on fillers for plastics.
Antioxidants, modifiers and antistatic additives: 3 listings#
3 listings reach the remaining additive families, and all 3 catch a monomer or an impurity rather than the additive itself: glycidyl methacrylate, listed for cancer on 27 January 2023, butylated hydroxyanisole, listed on 1 January 1990, and diethanolamine, listed on 22 June 2012. Glycidyl methacrylate (CAS 106-91-2) is the residual monomer in ethylene-acrylate-GMA impact modifiers and in styrene-acrylic epoxy chain extenders; it carries an EU food-contact clearance under FCM substance 220 with a specific migration limit of 0.02 mg/kg, and the polymers that carry it as a residual monomer are not themselves listed.
Butylated hydroxyanisole (BHA, CAS 25013-16-5) is listed for cancer, while butylated hydroxytoluene (BHT, CAS 128-37-0), the hindered phenol actually used in polyolefin stabilization, carries no Proposition 65 listing. The full range of hindered phenols and other classes that replaced BHA are compared on antioxidants for plastics.
Diethanolamine (CAS 111-42-2) and cocamide DEA were both listed for cancer on 22 June 2012. Diethanolamine occurs as an impurity in ethanolamide antistatic additives such as lauric diethanolamide, which is not itself listed. Never write that an impact modifier, a chain extender or an ethanolamide antistat is on the Proposition 65 list; the listed entity is always the residual monomer or the impurity it carries. The ethanolamide and glycerol ester chemistries used as antistatic agents for plastics are compared on that family page.
Complete List of Prop 65 Plastic Additives with CAS Numbers and Listing Dates#
The complete list below gives all 25 Proposition 65 entries that catch a plastic additive, with the CAS number where the listing carries one, the endpoint, the listing date and the safe harbor level where OEHHA has set one. The table counts listing entries that catch a substance intentionally added to a plastic, counts a chemical group entry as one listing, and excludes monomers, PFAS and photoinitiators.
Table T2: The 25 Proposition 65 plastic-additive listings
| # | Proposition 65 entry (as OEHHA words it) | Family | CAS | Endpoint | Date listed | Safe harbor level | Substance page |
|---|---|---|---|---|---|---|---|
| 1 | Di(2-ethylhexyl) phthalate (DEHP) | Plasticizers | 117-81-7 | cancer; developmental and male reproductive | 1 Jan 1988; 24 Oct 2003 | not established | DEHP (DOP, dioctyl phthalate) |
| 2 | Diisononyl phthalate (DINP) | Plasticizers | 28553-12-0 | cancer | 20 Dec 2013 | NSRL 146 µg/day (revised 1 Apr 2016) | DINP (diisononyl phthalate) |
| 3 | Di-isodecyl phthalate (DIDP) | Plasticizers | 68515-49-1; 26761-40-0 | developmental | 20 Apr 2007 | not established | DIDP (diisodecyl phthalate) |
| 4 | Di-n-butyl phthalate (DBP) | Plasticizers | 84-74-2 | developmental, female and male reproductive | 2 Dec 2005 | not established | DBP (dibutyl phthalate) |
| 5 | Butyl benzyl phthalate (BBP) | Plasticizers | 85-68-7 | developmental | 2 Dec 2005 | not established | BBP (butyl benzyl phthalate) |
| 6 | Di-n-hexyl phthalate (DnHP) | Plasticizers | 84-75-3 | female and male reproductive | 2 Dec 2005 | not established | no substance page yet |
| 7 | Chlorinated paraffins (average chain length C12, approximately 60 percent chlorine by weight) | Plasticizers | 108171-26-2 | cancer | 1 Jul 1989 | not established | SCCP (short-chain chlorinated paraffins), page pending |
| 8 | Antimony oxide (antimony trioxide) | Flame retardants | 1309-64-4 | cancer | 1 Oct 1990 | not established | antimony trioxide |
| 9 | Tris(1,3-dichloro-2-propyl) phosphate (TDCPP) | Flame retardants | 13674-87-8 | cancer | 28 Oct 2011 | not established | TDCPP, page pending |
| 10 | Tris(2-chloroethyl) phosphate (TCEP) | Flame retardants | 115-96-8 | cancer | 1 Apr 1992 | not established | TCEP, page pending |
| 11 | Tetrabromobisphenol A (TBBPA) | Flame retardants | 79-94-7 | cancer (Labor Code mechanism) | 27 Oct 2017 | not established | TBBPA (tetrabromobisphenol A) |
| 12 | Molybdenum trioxide | Flame retardants | 1313-27-5 | cancer (Labor Code mechanism) | 19 Mar 2021 | not established | molybdenum trioxide, page pending |
| 13 | Pentabromodiphenyl ether mixture DE-71 | Flame retardants | n/a | cancer | 7 Jul 2017 | not established | no substance page yet |
| 14 | Tris(2,3-dibromopropyl) phosphate | Flame retardants | 126-72-7 | cancer | 1 Jan 1988 | not established | no substance page yet |
| 15 | 2,2-Bis(bromomethyl)-1,3-propanediol | Flame retardants | 3296-90-0 | cancer | 1 May 1996 | not established | no substance page yet |
| 16 | Lead and lead compounds; lead | Heat stabilizers | group entry, no single CAS | cancer; developmental, female and male reproductive | 1 Oct 1992; 27 Feb 1987 | not established | lead in PVC, page pending |
| 17 | Titanium dioxide (airborne, unbound particles of respirable size) | Colorants | 13463-67-7 | cancer | 2 Sep 2011 | not established | titanium dioxide in plastics |
| 18 | Carbon black (airborne, unbound particles of respirable size) | Colorants | 1333-86-4 | cancer | 21 Feb 2003 | not established | carbon black in plastics |
| 19 | Cadmium and cadmium compounds; cadmium | Colorants | group entry, no single CAS | cancer; developmental and male reproductive | 1 Oct 1987; 1 May 1997 | not established | cadmium pigments, page pending |
| 20 | Chromium (hexavalent compounds) | Colorants | group entry, no single CAS | cancer; developmental, male and female reproductive | 27 Feb 1987; 19 Dec 2008 | not established | lead chromate |
| 21 | Talc containing asbestiform fibers | Fillers | n/a | cancer | 1 Apr 1990 | not established | talc, page pending |
| 22 | Silica, crystalline (respirable) | Fillers | n/a | cancer | 1 Oct 1988 | not established | no substance page yet |
| 23 | Butylated hydroxyanisole (BHA) | Antioxidants | 25013-16-5 | cancer | 1 Jan 1990 | not established | no substance page (contrast: BHT is not listed) |
| 24 | Glycidyl methacrylate | Impact modifiers and chain extenders (residual monomer) | 106-91-2 | cancer | 27 Jan 2023 | not established | ethylene-acrylate terpolymer, page pending |
| 25 | Diethanolamine; cocamide DEA | Antistatic additives (impurity) | 111-42-2 | cancer | 22 Jun 2012 | not established | lauric diethanolamide, page pending |
Safe harbor levels are published separately by OEHHA. Only DINP's no significant risk level is confirmed against the OEHHA safe harbor list and held in our source library; every other entry, including the BBP maximum allowable dose level cited in secondary sources, is marked "not established" here until it is verified directly against OEHHA's safe harbor list. "Not established" is never a statement that no safe harbor level exists, only that this page does not yet carry a confirmed figure. Polybrominated biphenyls are listed for cancer and for developmental toxicity as a legacy flame retardant; their listing date is not established here, so they are not counted among the 25.
Every listed substance above with a confirmed identity has a full regulatory matrix on the plastic additives database, which extends the CAS number, dosage and every other regulatory listing beyond Proposition 65 alone.
Which Plastic Additives Are Not on the Proposition 65 List?#
The non-phthalate plasticizers that replaced DEHP carry no Proposition 65 listing: DOTP (also sold as DEHT), DINCH and ATBC are all absent from the list of 31 July 2026, as are the ortho-phthalates DIBP and DCHP. BHT, the antioxidant that replaced BHA in most polyolefin formulations, is also absent, and asbestos-free talc and amorphous silica carry no listing, unlike the asbestiform and crystalline forms above.
Table T3: Proposition 65 status of the common alternatives
| Additive | Family | Replaces | Prop 65 status (list of 31 Jul 2026) | Rules that still apply | Substance page |
|---|---|---|---|---|---|
| DOTP / DEHT | Plasticizers | DEHP, DINP | not listed | not an SVHC | DOTP / DEHT (dioctyl terephthalate) |
| DINCH | Plasticizers | DEHP in sensitive uses | not listed | not an SVHC | DINCH (Hexamoll DINCH) |
| ATBC | Plasticizers | DEHP in food contact and toys | not listed | 21 CFR 181.27 prior sanction | ATBC (acetyl tributyl citrate) |
| DIBP | Plasticizers | n/a | not listed | REACH Annex XVII entry 51, 0.1 %, since 7 Jul 2020 | DIBP (diisobutyl phthalate) |
| DCHP | Plasticizers | n/a | not listed | CPSIA 16 CFR 1307, 0.1 % in toys and child care articles | DCHP, page pending |
| Triphenyl phosphate | Flame retardants | TDCPP, TCEP | not listed | SVHC since 7 Nov 2024 (endocrine disrupting, environment) | triphenyl phosphate |
| BHT | Antioxidants | BHA | not listed (BHA is listed) | EU FCM 315, SML 3 mg/kg; on CoRAP | BHT (butylated hydroxytoluene) |
| Amorphous silica, fumed and precipitated | Fillers and antiblock | crystalline silica | not listed | n/a | fumed silica, page pending |
| Talc, asbestos-free | Fillers | talc containing asbestiform fibers | not listed | RAC proposed Carc. 1B, not in CLP Annex VI | talc |
"Not listed" means no Proposition 65 warning duty today; it does not mean the substance is unregulated everywhere. DIBP is restricted under REACH Annex XVII entry 51 at 0.1 % in all EU articles since 7 July 2020, and DCHP is one of 8 phthalates limited to 0.1 % in children's toys and child care articles under the CPSIA, 16 CFR 1307. The Proposition 65 status of DOTP, DINCH and ATBC in this table is carried alongside the 31 July 2026 list-edition date, and this page rechecks that status at every OEHHA list republication.
How Much Triggers a Warning? Safe Harbor Levels for Listed Additives#
A Proposition 65 warning is not required when the exposure a product causes stays below that chemical's safe harbor level, which OEHHA sets as a no significant risk level for a cancer listing and a maximum allowable dose level for a reproductive listing. OEHHA publishes safe harbor levels for the full Proposition 65 list separately from the listing entries themselves, and this page states only the value it has confirmed directly, rather than reproducing an unverified figure. The European equivalent is a concentration in a food simulant rather than a daily intake; the specific migration limits (SML) that EU 10/2011 sets for the same plasticizer family are compared on that page.
No significant risk levels for the carcinogen listings#
The only no significant risk level our source library holds for a plastic additive is DINP's, at 146 micrograms a day, last revised on 1 April 2016. This figure is a daily intake set by OEHHA for the cancer listing, not a concentration inside the plastic part, so it cannot be converted into a weight percentage or a phr value without a specific exposure model, which this page does not attempt. For every other carcinogen listing in Table T2, OEHHA publishes a no significant risk level on its own safe harbor list, and this page directs a formulator to that source rather than repeating an unverified number.
Maximum allowable dose levels for the reproductive listings#
OEHHA sets a maximum allowable dose level for every reproductive-toxicity listing on the Proposition 65 list, covering developmental, female reproductive and male reproductive endpoints. A maximum allowable dose level works the same way as a no significant risk level: exposure below the published figure carries no warning duty. A value for BBP has circulated in secondary sources but is not confirmed against OEHHA's own safe harbor list, so this page states the mechanism and the endpoint types without quoting that figure, and points formulators to the OEHHA safe harbor page for the current, confirmed number.
Which Plastics Trigger Prop 65 Warnings? PVC, Polycarbonate and Flame-Retardant Compounds#
3 plastic families account for most Proposition 65 warnings on plastic products: flexible PVC, because it carries 5 to 65 wt% plasticizer and the 6 listed phthalates all soften PVC; polycarbonate, because of its monomer bisphenol A; and any flame-retarded compound built on a halogen donor with an antimony trioxide synergist. The full flexible and rigid formulation packages for the PVC family sit on additives for PVC.
Table T4: Polymers that most often carry a Proposition 65 warning
| Polymer | Listed additives it typically contains | Typical product that carries a warning | Note |
|---|---|---|---|
| Flexible PVC | DEHP, DINP, DIDP, DBP, BBP, lead stabilizers (legacy) | wire and cable, garden hose, flooring, coated fabrics, medical tubing | plasticizer content 5-65 wt% |
| Rigid PVC (legacy) | lead and lead compounds | legacy pipe and profile | EU limit below 0.1 % Pb since 29 Nov 2024 |
| Polycarbonate and PC/ABS | antimony trioxide in FR grades | electrical enclosures | additives for polycarbonate; BPA is a monomer, not an additive |
| Polypropylene | talc (asbestos-free grades not listed), titanium dioxide and carbon black as powders | automotive interior, appliance housings | powder-handling exposure only |
| Polyethylene | carbon black | pressure pipe at 2-2.5 wt% (ISO 4427), agricultural film | airborne unbound particles only |
| HIPS and ABS | antimony trioxide with a brominated donor, TBBPA | enclosures and housings | 5 wt% Sb2O3 with 10.7 wt% Br gives UL 94 V-0 at 0.8 mm in HIPS |
| Flexible polyurethane foam | TDCPP, TCEP | furniture, automotive and juvenile products | TDCPP listed 28 Oct 2011 |
Bisphenol A is the monomer of polycarbonate, not an additive, and it is the reason polycarbonate parts frequently carry a Proposition 65 warning; the listing history and the EU status of bisphenols in plastics are covered on that page rather than here.
What a Compliant Proposition 65 Warning Has to Contain#
The content of a Proposition 65 warning is set in Article 6 of Title 27 of the California Code of Regulations, and a warning that follows that text is presumed to be clear and reasonable. This page states the legal basis of the safe-harbor warning content without reproducing, paraphrasing or inventing the warning wording itself, the symbol requirement or the website address a safe-harbor warning must carry, because those specifics require direct verification against OEHHA's current warning guidance. OEHHA publishes the model warning language and the symbol specification on its own warnings site, cited in the sources below.
The short-form amendments of 1 January 2025 and the deadline of 1 January 2028#
The short-form Proposition 65 warning changed on 1 January 2025: it must now name at least one listed chemical, so a compounder's customer needs to know which listed additive is in the compound, not only that one is. OEHHA adopted these short-form warning amendments on 6 December 2024, and they took effect on 1 January 2025. A transition period runs to 1 January 2028; products manufactured and labelled by 31 December 2027 under the prior short-form wording may still be sold as labelled during that window. This date set is drawn from a legal bulletin tracking the OEHHA rulemaking and is carried alongside the "verified 22 September 2026" line at the top of this page.
How Do You Screen a Compound for Proposition 65? 7 Steps#
Screen a compound for Proposition 65 in 7 steps: list every intentionally added substance, add the residual monomers and impurities, match the CAS numbers against the list edition in force, separate the airborne-particle entries, check the safe harbor levels, agree who warns, then record the result.
- List every intentionally added substance in the formulation with its CAS number, including the carrier resin of each masterbatch.
- Add the residual monomers and known impurities named by the supplier, because glycidyl methacrylate and diethanolamine are listed while the additives that carry them are not.
- Match each CAS number against the OEHHA list edition in force, and match the metals against the group entries for lead, cadmium and hexavalent chromium; a plastic additive CAS number lookup speeds this step when a trade name needs resolving first.
- Separate the entries qualified as airborne unbound particles of respirable size, because they describe powder handling rather than the finished part.
- Check whether OEHHA has set a safe harbor level for each remaining entry.
- Agree with the customer who gives the warning, since the duty falls on the business causing the exposure in California, not automatically on the compounder.
- Record the result, the list edition date and the supplier evidence in a declaration.
Running a formulation through an additive regulatory status checker after step 7 catches a listing this manual process can miss, and it is the fastest way to re-screen a formulation whenever OEHHA republishes the list.
What Customers Ask Compounders For: The Prop 65 Declaration#
A Proposition 65 declaration is not a document defined by the statute: it is a supply-chain statement that a compounder gives a converter, listing which Proposition 65 chemicals are intentionally added above an agreed threshold, usually 0.1 %. Proposition 65 itself defines no declaration format and no 0.1 % threshold; both are commercial practice between a compounder and its customer, never a legal requirement of the statute, and this section describes that practice rather than a filing obligation.
Buyers typically ask a Proposition 65 declaration to state 4 things:
- The listed chemicals intentionally added to the compound above the agreed threshold
- The threshold applied, often 0.1 % or a statement that no listed chemical is intentionally added
- The OEHHA list edition the check was made against
- The date the check was carried out
This declaration is distinct from the EU declaration of compliance (DoC) for plastic food-contact materials, which Regulation (EU) No 10/2011 does define as a legal document; the Proposition 65 declaration carries no equivalent legal definition.
How Proposition 65 Fits the Other Plastic Additive Regulations#
Proposition 65 is the only one of these rules that never limits a concentration: REACH Annex XVII, the CPSIA and the FDA food-contact rules each set a numeric limit in the article, while Proposition 65 sets a duty to warn about an exposure. Every instrument that reaches a plastic additive is indexed under plastic additive regulations, which this comparison draws from directly.
Table T5: Proposition 65 against the other plastic additive rules
| Rule | What it controls | Trigger | Numeric limit | Consequence of non-compliance |
|---|---|---|---|---|
| California Proposition 65 | exposure | a knowing and intentional exposure in California by a business with 10 or more employees | none; safe harbor levels are daily intakes | warning duty, enforced through 60-day notices |
| REACH Annex XVII entry 51 | content of the article | placing on the EU market | 0.1 % by weight of plasticized material, since 7 Jul 2020 | the article may not be placed on the market, see REACH Annex XVII restrictions |
| REACH Annex XVII entry 52 | content of the article | mouthable toys and child care articles in the EU | 0.1 % | the same, limited to those articles |
| CPSIA 16 CFR 1307 | content of the accessible plasticized component | children's toys and child care articles in the US | 0.1 % (1,000 ppm) for 8 phthalates | the product may not be sold, see CPSIA phthalate limits |
| FDA 21 CFR 174-178 | use in food contact | food-contact use in the US | per-section limits by polymer and condition of use | the use is not authorized, see FDA food contact rules |
Proposition 65 also overlaps with 2 additional US instruments that reach the same phthalate group by a different mechanism. The FDA's final rule of 20 May 2022 keeps exactly 8 ortho-phthalates authorized as food-contact plasticizers, and the EPA published final TSCA risk evaluations for BBP, DBP, DCHP, DEHP and DIBP with a Federal Register notice of 6 January 2026 (91 FR 373), finding unreasonable risk to workers; TSCA and plastic additives reaches 5 of the same phthalates through that separate route.
PFOA and PFOS carry their own Proposition 65 listings, PFOA for developmental toxicity on 10 November 2017 and for cancer on 25 February 2022, PFOS for developmental toxicity on 10 November 2017 and for cancer on 24 December 2021, but neither is used as a plastic additive, so neither counts among the 25 entries above; PFAS restrictions and plastic additives covers that separate chemical class in full.
What Changed on the Proposition 65 List, and What Changes Next#
The most recent Proposition 65 listing that reaches a plastic additive is glycidyl methacrylate, added for cancer on 27 January 2023, and the most recent change to the warning itself took effect on 1 January 2025.
Table T6: Change log relevant to plastic additives
| Date | Change | Additive affected | Status |
|---|---|---|---|
| 1 Jan 2028 | end of the short-form warning transition | all | scheduled |
| 8 Dec 2025 | BPS listed (developmental) | polycarbonate monomer, context only | in force |
| 3 Jan 2025 | BPS listed (male reproductive) | monomer, context only | in force |
| 1 Jan 2025 | short-form warning amendments take effect | all | in force |
| 29 Dec 2023 | BPS listed (female reproductive) | monomer, context only | in force |
| 27 Jan 2023 | glycidyl methacrylate listed (cancer) | reactive impact modifiers, chain extenders | in force |
| 19 Mar 2021 | molybdenum trioxide listed (cancer) | smoke suppressant and flame retardant | in force |
| 18 Dec 2020 | BPA listed (developmental) | monomer, context only | in force |
| 27 Oct 2017 | TBBPA listed (cancer) | brominated flame retardant | in force |
| 7 Jul 2017 | pentaBDE mixture DE-71 listed (cancer) | legacy flame retardant | in force |
| 20 Dec 2013 | DINP listed (cancer), NSRL 146 µg/day set | plasticizer | in force |
BPA and BPS are monomers, not additives, and are listed here only as context for the change log; neither is counted among the 25 additive listings. No forecast of future listings appears on this page, because OEHHA's "chemicals under consideration" data is not part of the confirmed sources; the only forward-dated item stated with certainty is the short-form transition deadline of 1 January 2028. This page carries the list edition of 31 July 2026 and was last checked for regulatory status on 22 September 2026.
Should You Worry About a Prop 65 Warning on a Plastic Product?#
A Proposition 65 warning tells you that a product can expose you to a chemical California has listed as a carcinogen or a reproductive toxicant; it does not tell you how much of that chemical the product contains, because Proposition 65 sets no concentration limit. The health evidence behind each listed chemical, beyond what this compliance page covers, sits on toxic plastic additives.
Why do so many plastic products carry a Proposition 65 warning?#
3 structural features of Proposition 65 explain why warnings appear on so many plastic products: group entries, the concentration of listings in the plasticizer family, and enforcement by private 60-day notices. The group entries for lead, cadmium and hexavalent chromium each catch a whole metal chemistry at once rather than a single named substance. Six of the most widely used plasticizers are listed while flexible PVC itself carries 5 to 65 wt% plasticizer, so almost any flexible PVC part touches at least one listing. Enforcement runs mainly through private 60-day notices rather than government inspection, which pushes suppliers toward warning defensively even in borderline cases.
What chemicals are in a Prop 65 warning on plastic?#
A Proposition 65 warning on a plastic product most often names DEHP or DINP in flexible PVC, lead in a legacy rigid PVC part, antimony trioxide in a flame-retarded housing, or TDCPP in polyurethane foam. These 5 substances cover the great majority of Table T2's entries that reach a mainstream plastic product; the health effects behind the phthalate group specifically are covered on phthalates: health effects.
Is it okay to use a product with a P65 warning?#
A Proposition 65 warning is a disclosure rather than a safety verdict: it states that an exposure to a listed chemical can occur, and it carries no statement about the quantity in the product or the risk at that quantity. The law does not measure or cap how much of the chemical the article contains, so the warning alone gives no basis for a risk judgment. A risk assessment for a specific chemical, rather than a compliance answer, sits in the health evidence directly, not on the warning label.
Does a Proposition 65 listing mean the additive is banned?#
No: a Proposition 65 listing bans nothing, and DINP shows the difference clearly, because it is listed for cancer in California, restricted in the EU only in mouthable toys and child care articles, and still authorized by the FDA as a food-contact plasticizer. The actual bans and concentration limits that do apply to phthalates worldwide, rather than a warning duty, are mapped on phthalate restrictions worldwide.
How Proposition 65 changed plastic formulations#
Proposition 65 pushed formulators toward additives with no listing, which is why DOTP, DINCH and ATBC replaced listed ortho-phthalates in California-facing products and why lead stabilizers became legacy chemistry in PVC. No study in our source library quantifies the size of this reformulation effect across the industry, so this page states the direction of the shift and the named substitutes rather than a percentage. The full replacement logic, including when a non-listed substitute is technically interchangeable with a listed one, is worked through on how to select plastic additives.