Holiday Products Most Likely to Be In Scope of Proposition 65

Holiday Products Most Likely to Be In Scope of Proposition 65

Designed to protect the public from toxic chemical exposure, the Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65) requires businesses operating or selling in the state of California to notify the public about the presence of chemicals that may adversely affect reproductive health, or cause cancer or birth defects.

While few things signify the holiday season has begun like the appearance of twinkling lights on houses, inflatable characters on front lawns and fake snow on window panes, companies that bring this season to life must be aware of their risks for non-compliance under Proposition 65. We’ve come a long way from lead in tinsel and fake snow made of asbestos, however, there are still many products likely to be in scope.

String Lights  

Makers of strings of lights have two avenues of concern. First, the electronic workings of the wires, which may contain lead. Second, the PVC vinyl coating encasing them, which may contain phthalate plasticizers. All products containing vinyl-sheathed power cords and electronic cables can expose users to plasticizers, many of which are listed under Proposition 65.

Artificial Greenery 

Companies selling artificial trees and wreaths must be aware of the potential presence of lead in the metal framing of their products, and potential phthalate plasticizers in the plastic needles.


Companies that produce toys and other children’s products have a higher standard than most for manufacturing products that are safe to use. The plastic components in toys are often at risk of containing plasticizers, and any electrical components may contain lead.

Technology-driven gift manufacturers must be aware of any lead or plasticizers present in headphones and other electronics.

Formal Table Dressings 

Many people come together over the holiday season to have dinner over more formal table dressings. Glassware manufacturers that use lead oxide to increase sparkle must declare the presence of lead. Further, glazed dishes with yellow, red or black may contain pigments with heavy metals such as lead or cadmium.

Products used during meal preparation such as non-stick pans can have coatings that, when heated to high temperatures, can break down to release carcinogenic fumes. Perfluorooctanoic acid (PFOA) is less common now, but non-stick cookware manufacturers must declare if their products still use PFOA or any similar chemicals in scope of Proposition 65.

Winter Clothing

Winter clothing manufacturers may have products with zippers and buttons containing brass or lead. Meanwhile, leather goods such as snowmobile apparel may use hexavalent chromium during the tanning process.

The holiday season is a busy time for retailers and manufacturers, so to avoid unpleasant surprises in the new year that can affect long-term business success, it is imperative that products put onto the market are compliant with all relevant regulations.

To learn how Assent’s Proposition 65 Module can help you maintain compliance and mitigate risks associated with product composition, email