SGS Answers Questions About Furniture Compliance and California Proposition 65
SGS experts answer some of the main questions raised by furniture manufacturers in relation to compliance with Prop 65.
Furniture can be made from a wide variety of components and materials. Legs may be metal, frames may be composite wood, and coverings may be woolen, each may also have different coatings, stains, sealants or lacquers. To comply with Prop 65, the manufacturer needs to be sure each of these is complaint with its requirements.
Manufacturers of products that are made from multiple materials can take one of two approaches to assessing whether their product complies with Prop 65:
· Risk-based assessment – involves testing only for high-risk chemicals as shown by looking at Prop 65 settlements. High-risk substances have traditionally included lead, phthalates, formaldehyde, and PU foam and fabric flame retardants. SGS also reminds stakeholders that they should be aware bisphenol A (BPA) and hexavalent chromium VI are now also regularly targeted.
· Product-based assessment – unique to SGS. This service considers all the chemicals listed under Prop 65, giving greater assurance to manufacturers
A common area of concern is whether a Prop 65 warning is required if furniture foam is completely covered. The answer is, it is because chemical exposure is not restricted to direct skin contact. It also includes inhalation and ingestion.
Another area of misunderstanding relates to EU/UK fire safety regulations that restrict flame retardants in PU foams. Stakeholders therefore wonder if the same products can be used in California but with the warning label. The difference is, Prop 65 does not ban chemicals. Prop 65 merely makes businesses responsible for providing clear and reasonable warnings on products containing listed chemicals that may cause cancer or reproductive harm.
In a similar way, EU REACH test methods are not acceptable for Prop 65. Prop 65 provides a safe harbor level to guide businesses in determining whether a warning is necessary. Safe harbor levels reference a daily exposure limit (µg/day). This is completely different to the chemical total content of a product (mg/Kg) that is used in REACH, and the one cannot be converted into the other.
A full list of settlements and 60-day notices can be found on the California Attorney General's website.
To learn more about Prop 65, read SGS's Q&A "Understanding California Proposition 65: Commonly Asked Questions (https://www.sgs.com/
Learn more about SGS's Prop 65 (http://www.sgs.com/
For more information, please contact:
Technical Manager - Restricted Substances
Tel: +1 (973) 461 7950