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California 6510 Frequent Questions Q&A
Author.
LCS
Source:
http://en.lcs-cert.com/
Post time:
2018-12-19
1.Q: What is California 65?
A: California 65 is California's proposal to increase concerns about toxic chemicals that can be contacted, referred to as California 65 proposal.
In November 1986, California enacted the Drinking Water Safety and Toxic Substances Enforcement Act 1986, which was later codified in Chapters 25249.5-25249.13 of the California Health and Safety Code.
2.Q: What are the requirements of California 65? How should the products meet the requirements of California 65?
A: California 65 currently controls nearly 1,000 substances, and the list of substances does not set a limit. For enterprises, it is difficult to fully control such a huge amount of material. In addition, quarterly renewal of controlled material is also one of the difficulties.
LCS suggests that enterprises find out the limitation requirements for such products in existing lawsuits according to the type of products, and investigate the content of their products to determine whether they meet the limitation requirements for harmful substances in relevant lawsuits. If the restricted substances exceed the limits of relevant litigation cases, enterprises should put warning labels on their products. Currently, California 65 related lawsuits involve many types of products in various fields such as electronics, electrical, toys, food contact materials, etc.
3.Q: If the product passes the test of phthalate esters related to California Act 65, do you think it meets the requirements of four new phthalate esters added to RoHS?
A: I don't think so. There are differences in the scope of control, control limits, control substances and test methods between the two regulations. Therefore, it is necessary to test and judge whether the requirements are met separately.
4.Q: How are the current limits of California Act 65 defined? Are there any specified limits? Where are these limits authoritative? What are the limits on DINP? When will they come into effect?
A: The California 65 Act has been in force since 1986. There is no clear limit in the Act. The limit comes from litigation cases (judgments after consumers sue enterprises). There is no official website for the litigation cases.
DINP limits vary according to the product.
If you are interested in studying this regulation, it is suggested that you should know it through the following official websites:
Https://oehha.ca.gov/proposal-65
5.Q: California Act 65 banned more than 900 substances in the list, but many testing institutions are mostly based on the material and limits of court decisions. If antimony trioxide (CAS No. 1309-64-4) is included in the product list, the proportion added is at least 10,000 ppm. In this case, does the product meet the requirements of California 65?
A: Most electronic companies are controlled by referring to California's 65 prosecution cases. Control substances and limits are derived from prosecution cases. Although none of the existing cases have been prosecuted for antimony trioxide exceeding the standard. But antimony trioxide is a carcinogen and is on California 65's list, which does not rule out future consumer concerns. Considering the risk, LCS suggests that enterprises first investigate the use of the substance in various materials through supply chain investigation, and then gradually reduce or even ban the substance in the subsequent process.
6.Q: If an enterprise is a manufacturer or producer of consumer goods but does not sell directly to retailers, how should it meet the retailer's warning requirements?
A: Enterprises that do not sell directly to retailers have two eligible choices:
(1) Identify products with necessary warnings;
(2) Provide warning notices and warning materials to packers, importers, suppliers or distributors.
If the second item is adopted, enterprises should ensure that warning information can be transmitted along the supply chain and eventually reach consumers. The manufacturer or manufacturer may choose to sign contracts with other enterprises in the other business chain to ensure that their products can properly communicate warnings to retailers and end consumers.
7.Q: How to determine whether a California 65-list substance is carcinogenic or reproductive toxic or has both characteristics?
A: Enterprises can view or download the complete list of California 65 by visiting the official website of California 65 List. The toxicological characteristics of related substances are listed in the column of "Toxicity Categories":
Https://oehha.ca.gov/proposal-65/proposal-65-list
8.Q: California Proposal 65 calls for standard format warnings to reflect "one or more" harmful substances. If a company determines that there are five California 65 lists of substances that need to be warned, do all five substances need to be reflected in the warning?
A: If all five substances are carcinogens, enterprises can only reflect the name of one of the five substances in the warning, or they can choose to embody any or all four of the other four substances at the same time.
If the five substances include both carcinogenic and reproductive toxic substances, enterprises can only embody the name of one carcinogenic substance and one of the reproductive toxic substances in the warning, and can choose to embody more substance names in the warning.
If a substance has both carcinogenic and reproductive toxicity, the warning only needs to reflect the name of the substance and both carcinogenic and reproductive toxicity. Enterprises can also choose to reflect more names of substances.
9.Q: Can chemical abbreviations be used in warning labels? For example, if a product needs to provide warning labels for "diethylhexyl phthalate", can the abbreviation "DEHP" be used in warning labels instead of the full name of the substance?
A: The names in the warning signs need to be consistent with those in California's official list of 65.
If the abbreviation is part of the full name of the chemical substance and is reflected in the warning label, it can be used separately in subsequent references.
10.Q: If enterprises can't print in color, can they print triangular warning signs in black and white?
A: If the enterprise does not use yellow printing for other information of the label, the triangular warning signs can be printed in black and white.
About Lixun Chemicals Department of Consumer Goods Testing
Consumer Chemistry Department (hereinafter referred to as the Chemical Department) is a comprehensive department which is carefully built by Lixun Testing Group and integrates testing, consulting, training and technical services. At present, the laboratory has been approved by CNAS, which can provide one-stop environmental protection compliance services for all sectors of society. The Ministry of Chemistry is committed to providing high-quality, convenient and efficient services, helping enterprises to promote green environmental protection, and providing strong support and guarantee for the smooth global flow of enterprise products.
Contact Way of Consumer Chemistry Department
Mr. Peng: 15019245002
Consultation mailbox: Dick@lcs-cert.com
Shenzhen Lixun Testing Co., Ltd. has been focusing on testing and certification services for 14 years. We can provide you with efficient and reliable certification services in the United States (OSHA NRTL, FCC, ENERGY STAR), Canada (ISED), European Union (CE), Korea (KC), Japan (MIC), Singapore (IMDA), Hong Kong (OFCA), Taiwan (NCC, BSMI), Egypt (NTRA), Vietnam (MIC), Saudi Arabia (SASO), Philippines (NTC), Thailand (NBTC), Malaysia (SIRIM), India (BIS/WPC/TEC) and other countries to protect your products against international trade barriers. Today, with the increasing intensity, we are still smoothly entering the international trade market!
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