For any brand selling textile goods in California, Proposition 65 isn’t just legal noise — it’s something that can cost you, quickly and quietly. Many in the industry don’t pay attention until they receive a notice of violation. At that point, it’s often too late to fix the issue without taking a financial hit.
Passed in 1986, Prop 65 was designed to help consumers make informed choices about chemical exposure. The law requires businesses to warn Californians if their products contain chemicals known to cause cancer, birth defects, or reproductive harm. Over 900 substances are currently on the list, and it’s updated regularly. Apparel and textile goods may not seem like obvious candidates, but they often fall under this regulation.
Where the Risk Lies in Textile Products
Textiles can contain restricted chemicals at various points in the supply chain — not always where you’d expect. Formaldehyde in anti-wrinkle finishes. Phthalates in plastisol prints or synthetic leather. Lead in pigments, screen-printed designs, or even metal snaps. Azo dyes used on certain fabrics can also break down into compounds listed under Prop 65.
The issue isn’t always the base material. It’s the treatment, the trims, the ink, or the accessories. And when your product includes a blend of components sourced from different vendors — fabrics from one mill, buttons from another, labels from a third — you’re introducing multiple layers of potential non-compliance.
How Apparel and Accessories Can Trigger a Prop 65 Violation
Unlike federal regulations, Prop 65 is enforced in part by private groups. That means a law firm or advocacy group can order a product off the shelf, test it, and issue a 60-day notice if they find something over the allowable limit. These notices often lead to settlements. That could mean fines, relabeling, and, in some cases, pulling entire shipments. Even large, well-known brands have been caught off guard.
And here’s the frustrating part: the burden of proof is on the business. If you want to claim your product is safe, you need test results to back that up. It’s not enough to say “our supplier assured us it’s fine.” That won’t hold up in court — or with California regulators.
What Proposition 65 Requires from Textile and Apparel Brands
The law doesn’t ban products. It doesn’t even ban the use of listed chemicals. What it requires is transparency. If your product exposes a consumer to a listed substance above the “safe harbor” level, you need to include a warning.
The standard language includes the name of the chemical and a link to California’s Prop 65 website. It has to appear on the product, the packaging, or the website where the item is sold. Some companies choose to label everything out of caution. Others rely on lab testing to determine if the label is necessary.
There’s no one-size-fits-all answer. But over-labeling can create other problems. Consumers may view the warning as a sign that the product is dangerous, even when it’s not. Retailers may push back, especially if labeling hasn’t been coordinated in advance.
Why Product Testing Is Essential for Proposition 65 Compliance
If you’re manufacturing or importing textile products into the U.S., and California is part of your market, you need to build chemical testing into your QA process. That means testing both finished goods and, where possible, individual components. Trim, print, fabric, coating — each may need to be verified.
Start by identifying your highest-risk materials. Synthetic leathers, coated fabrics, plastic-based prints, accessories with metal finishes — these should be tested first. Use ISO or ASTM-aligned methods, and work with accredited labs. Keep all test reports on file, and make sure your suppliers can produce supporting documentation as well. Safety Data Sheets (SDS) are useful, but they’re not always enough.
Avoiding Trouble Starts with Your Supply Chain
Compliance doesn’t start at the final textile inspection. It starts when you choose your vendors. If your supplier can’t answer questions about chemical finishes or component sourcing, that’s a red flag. Some suppliers will promise compliance but can’t produce evidence. Others genuinely don’t know what’s in the inks or adhesives used by their subcontractors.
That’s why it helps to include chemical compliance in your supplier agreements. Spell it out. Reference Prop 65 specifically. Ask for material disclosures and third-party testing where needed. Some brands also require suppliers to sign a compliance declaration, acknowledging their role in risk management.
Final Thoughts: Staying Ahead of Prop 65 in the Textile Industry
California Proposition 65 isn’t something you can ignore just because you manufacture overseas or sell mostly outside the U.S. If your product ends up in California — in a store, online, or in a warehouse — it needs to comply. The enforcement landscape is active, the list of chemicals is long, and the risk of legal action is real.
But with proper testing, clear supplier expectations, and consistent documentation, compliance is manageable. Don’t wait for a warning letter to take it seriously. Build it into your workflow now, and avoid bigger problems down the line.
