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Participant

Join Date: Jul 2007
Posts: 2

California Proposition 65 Compliance?

07/19/2007 11:21 PM

We're a startup manufacturer of consumer electronics gadgets. We've recently been asked if we comply with California Proposition 65, the "Safe Drinking Water and Toxic Enforcement Act of 1986" (http://www.oehha.ca.gov/prop65.html).

We're not RoHS compliant and we use industry standard materials on our PCBs. Our Chinese contract manufacturer reports they have never been asked about Prop 65 compliance and can't advise us how to proceed.

Come to think of it, I've never seen any CE product with a "This product contains chemicals known to the State of California to cause cancer and birth defects or other reproductive harm."

How should we proceed?

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Guru

Join Date: Feb 2006
Location: Piney Flats, Tennessee
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#1

Re: California Proposition 65 Compliance?

07/20/2007 7:01 AM

Contact all your suppliers for certifications.

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Guru

Join Date: Jul 2006
Location: "Dancing over the abyss."
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#2

Re: California Proposition 65 Compliance?

07/21/2007 1:59 AM

Actually the governor just signed a bill even more onerous than Proposition 65. It bans lead PERIOD for anything touching a water supply. So no Traditional brass for you. I will look it up when I return to work monday. They are still fussing over due dates, definitions, and enforcement on some Clarifying bills trying to amend this, but it was passed and signed...

However you said you you make consumer electronics gadgets: I'm not sure how retail sales of electronics constitutes a measureable release to the water supply from a technical point of view (No legal advice here, just technical!) and the applicability of that to your products.

If you live in the same world that I do, you'd be working on getting RoHS compliant as soon as possible. and by the way, China has a RoHS law now too that while it doesn't seem to ban the Chinese from making and exporting products from materials that don't comply, will not let your product in if it doesn't comply.

I would also post this question on the electrical engineering forum, those guys are up to date on do's and don'ts on lead free solders (and their problems).

Catch you Monday.

milo

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Participant

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#4
In reply to #2

Re: California Proposition 65 Compliance?

07/23/2007 9:05 AM

Thanks for this response. We're very familiar with RoHS and we've already converted some of our products to be RoHS compliant. My question is about inventory we have sitting in a warehouse RIGHT NOW! We have a retailer who wants to buy from this inventory and we need to know how to respond to the Prop65 question.

Has anyone else on this thread been asked about Prop65? How did you respond?

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Guru

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Location: "Dancing over the abyss."
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#5
In reply to #4

Re: California Proposition 65 Compliance?

07/23/2007 10:19 AM

You did not say what exactly your products are.

Prior to $pending big buck$ for a legal opinion, one way for you to see what is required is to see what warnings are on similar products that are sold in california.

If you have sales reps there, have them purchase competitors products; otherwise, send out an engineer or your compliance officer to "lotus -land" and have them do some asking while they are out buying similar products. A trip to best buy or CompUSA or a few Radio Shack stores ought to give you a sense of whether ort not this bill applies to your products. They just need to look and see what kind of labelling is on similar goods. Have you any suppliers in CA? ANy other Customers?

milo

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Power-User

Join Date: Apr 2007
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#3

Re: California Proposition 65 Compliance?

07/21/2007 3:35 PM
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benres (1); dadw5boys (1); Milo (2); reefdiver (1)

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