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If you manufacture or import electronic products into California, Proposition 65 labeling isn’t optional — it’s legally required. For electronics brands, these warning labels can impact everything from shelf presence to liability risk.
But what exactly must the label say? When is it required? And how does it apply to circuit boards, solder, or plastic enclosures?
Let’s break it down.
What Triggers a Prop 65 Label for Electronics?
California’s Safe Drinking Water and Toxic Enforcement Act of 1986 — better known as Proposition 65 — requires warnings for any product that can expose consumers to one or more listed chemicals. The California warning label requirement applies to a wide range of products sold in the state — from electronics and apparel to food packaging and industrial equipment
For electronics, this includes:
- Lead in solder or component terminals
- Cadmium in circuit boards
- Phthalates (DEHP, BBP, DBP, DIBP) in cable insulation or plastic housings
- Flame retardants in circuit board laminates
Even trace exposures (above Safe Harbor Levels) can trigger the need for a warning.
Prop 65 Label Requirements for Electronics
- When a Label Is Required
- If your product contains a listed chemical and exposes users (via touch, dust, fumes, or deterioration) during normal or foreseeable use.
- If no exemption applies (e.g., Safe Harbor Levels or federal preemption).
Label Must Include:
- Clear warning symbol (black exclamation in a yellow triangle)
- “WARNING: This product can expose you to [chemical name], which is known to the State of California to cause [cancer/birth defects].”
- A link to www.P65Warnings.ca.gov
Example:
WARNING: This product can expose you to lead, which is known to the State of California to cause cancer and birth defects. For more information go to www.P65Warnings.ca.gov.
Where to Place the Label on Electronics Packaging
- On the product box
- Or on the product itself, if no outer packaging
- Online listings must also show the warning prior to purchase
Placement Tip: Warnings must be visible without the customer opening the package.
Prop 65 Warning Types for Electronics
Penalties for Missing or Incorrect Prop 65 Labels
- Civil penalties: $2,500 per violation per day
- Lawsuits from private citizens or advocacy groups
- Product delisting or sales blocks by retailers
How Acquis Supports Prop 65 Labeling for Electronics
Acquis helps electronics manufacturers ensure compliance across their supply chain:
- Track listed substances in materials, components, and finished goods
- Automate Safe Harbor screening
- Generate product-specific warnings and label templates
- Stay ahead of chemical list updates with compliance alerts
Whether you’re labeling 10 SKUs or 10,000, Acquis turns Prop 65 into a manageable process — not a risk exposure.
Get Prop 65 Labeling Support for Your Products
Unsure if your electronics need a Prop 65 label? Let our compliance team run a product review — and generate label templates for every risk scenario.
