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California’s Prop 65 Law Update

March 7, 2018

Steve asks,

Would you have any information in regards to changes in California’s Proposition 65 law?  These are changes in labeling and marketing requirements for products that contain ingredients known to the State of California to cause cancer and/or reproductive harm, and I’m specifically interested in any known requirements from corrugated convertors and/or harmful ingredients in corrugated.

Here is the list of Chemicals Known To The State To Cause Cancer Or Reproductive Toxicity sent to us from our customer. They also provided a list of all the products we make for them in which we must disclose any products that have chemicals that appear on the other list.

Below is a related article for your readers’ reference:

https://www.exponent.com/knowledge/alerts/2017/08/prop-65-changes/?pageSize=NaN&pageNum=0&loadAllByPageSize=true

Our understanding is that as long as none of the materials used to manufacture the box (paper, starch, ink, glues, tapes or staples, etc.) have any of the chemicals that appear on the Proposition 65 list then you are okay and should not need to add any additional markings to the box.

Reach out to your suppliers and put the responsibility on them to certify the materials they provide comply with Prop 65. They would be the best source to know what is in the raw materials. You probably already request and keep on hand Safety Data Sheets from each of your suppliers. It’s always good to keep these on file and up to date just in case a question ever arises. Also in today’s legal environment, it’s important to have a paper trail to protect yourself and your company.

As far as the products contained in the box, it is up to your client to disclose their product warnings based on what they put into the box.

If any of our readers would like to share their knowledge and experience with California’s Proposition 65 Law, send us a comment. Our community is best when we all participate!

— Ralph

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