U.S. – September 2025 California Proposition 65 – 60-Day Notices Analysis

In September 2025, California issued 520 Proposition 65 60-day notices with 50.8% involving Lead, 10% Phthalates, and 38.9% other chemicals. Notices also addressed combined chemical presence. Intertek offers Prop 65 compliance services supporting manufacturers and distributors to meet regulatory requirements and manage enforcement risks.

The Safe Drinking Water and Toxic Enforcement Act of 1986, commonly referred to as Proposition 65 (Prop 65), is enforced by the California Attorney General’s office or any district attorney or certain city attorneys or by any individual acting in the public interest. Prop 65 requires that an individual acting in the public interest, to enforce the Act give notice of the impending action to the person alleged to be committing the violation, along with the Attorney General, district attorneys and certain city attorneys in which the violation is alleged to have occurred. The notice must be sent to these parties no less than 60 days before commencing the action; thus, this notice is commonly referred to as the “60-day Notice of Violation”.

In September 2025, there were 520 60-day notices for violation of Prop 65, of which 50.8% of the notices (264 notices) served were for the category of Lead, 10.00% of notices (52 notices) were served for the presence of Phthalates, 38.9% of the notices (202) were for the presence of other chemicals. Also, 0.4% of notices (2 notices) were served for the combined presence of Lead and Phthalates.  

Among the reported notices, in the category of bags and cases, there were 18 notices for the presence of Phthalates, 1 notice for the presence of Lead and 2 notices for the presence of Perfluorooctanoic Acid (PFOA). Externally decorated glass and ceramics had 15 notices for the presence of Lead. In the category of footwear, there was 1 notice issued for the presence of Phthalates, and 1 notice for the presence of Hexavalent Chromium.

The beauty and personal care category had 2 notices for the presence of other chemicals such as Diethanolamine and Perfluorooctane Sulfonate (PFOS) in various products such as mascara, creams, hair gels, wipes, liners, masks etc. There were 6 notices issued for the presence of lead in toothpaste and tincture. In the category of hardware, 4 notices were issued for the presence of lead, 2 notices were issued for the presence of Phthalates and noticeably, 1 notice for the presence of Perfluorooctanoic Acid (PFOA).

In the category of gloves, there were 2 notices issued for the presence of Hexavalent Chromium, 1 notice issued for the presence of Perfluorooctanoic Acid (PFOA), and 2 notices issued for the presence of phthalates. There were 3 notices issued for the presence of Perfluorooctanoic Acid (PFOA) in apparel such as t-shirts and shorts, and 1 notice for the combined presence of Perfluorononanoic acid (PFNA) and its salts, Perfluorooctanoic Acid (PFOA) in jackets.

There were 117 notices issued for the presence of Bisphenol S (BPS) in receipts. Further, there were 2 notices for the combined presence of Bisphenol A and Bisphenol S in receipts.

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U.S. – August 2025 California Proposition 65 – 60-Day Notices Analysis