FLUKE
Kimball Electronics
Tolomatic
Industrial Scientific
AHEAD
roboception
FLUKE
Kimball Electronics
Tolomatic
Industrial Scientific
AHEAD
roboception
By Deepa Shetty | Fri Jun 6 2025 | 2 min read

Table of Contents

For electronics manufacturers selling into California, understanding what counts as exposure under Proposition 65 isn’t just a legal necessity it’s a critical part of product strategy. While it’s easy to assume that “exposure” refers only to chemicals leaking or spilling, Prop 65 takes a much broader view.

If your device contains even trace amounts of listed chemicals and a consumer can come into contact with them under reasonably foreseeable use you’re likely on the hook for a Prop 65 warning.

What Does “Exposure” Mean Under California Proposition 65?

Under Prop 65, “exposure” refers to any pathway through which a listed chemical enters the body, including:

  • Inhalation (e.g. fumes from solder or circuit board coatings)
  • Ingestion (e.g. accidental transfer of substances from hand to mouth)
  • Dermal absorption (e.g. touching a plastic casing containing phthalates)

And here’s the kicker: It doesn’t matter if your product is sealed or rarely touched. If regulators determine there’s a reasonably foreseeable route of exposure during normal use, maintenance, repair, or disposal — you're responsible.

Real-World Exposure Scenarios for Electronics

Here are examples of how Prop 65 defines exposure in common electronics use cases:

Here are examples of how Prop 65 defines exposure in common electronics use cases.PNG

When Is a Prop 65 Warning Required?

A Prop 65 warning is required before exposure occurs, which means manufacturers must:

  1. Assess the likelihood of exposure through normal or foreseeable use.
  2. Determine if any listed substances are present in the product or its components.
  3. Quantify exposure levels (if defending against the need for a warning).
  4. Issue a clear and compliant warning if thresholds are exceeded or testing isn’t conclusive.

If your exposure levels are below Safe Harbor Limits, you may not need a warning but the burden of proof lies with you.

Testing & Exposure Assessments: What’s Enough?

Prop 65 doesn’t mandate a specific testing protocol, but enforcement agencies and private plaintiffs expect a rigorous scientific approach. That includes:

  • Material declaration review
  • Laboratory testing and toxicological assessment
  • Exposure modeling or risk assessment reports
  • Documentation of use scenarios

If you're relying solely on supplier declarations without verifying exposure potential across product use stages you’re exposed.

Stay Ahead with Acquis: Exposure Risk Mitigation Made Scalable

Acquis helps electronics manufacturers de-risk Prop 65 exposure issues with a compliance automation platform built for real-world complexity.

We help you:

  • Conduct SVHC and Prop 65 chemical screenings
  • Automate risk-based exposure assessments
  • Manage Safe Harbor evaluation and warnings
  • Generate customer-ready Prop 65 documentation

Let us turn complex exposure evaluations into proactive compliance.

Not sure if your electronics products meet Prop 65 exposure thresholds? Let’s find out.

Book a Free Exposure Risk Consultation

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Understanding "Exposure" Under Prop 65

Exposure under Prop 65 means any pathway such as inhalation (e.g., fumes from solder), ingestion (e.g., hand-to-mouth transfer), or dermal absorption (e.g., touching phthalate-containing plastic casings) through which a listed chemical enters the body during normal use, maintenance, repair, or disposal, even if the product is sealed.
A warning is required if a listed chemical is present and exposure above safe harbor levels is reasonably foreseeable. Manufacturers must assess use cases, test for chemicals, quantify exposure, and provide a compliant warning when New- Safe Harbour levels are exceeded or test results are inconclusive.
Electronics often contain lead (in solder), cadmium (in resistors), phthalates like DEHP/DBP/BBP (in cables or coatings), flame retardants (e.g., TBBPA), vinyl acetate, bisphenol S (BPS), and molybdenum trioxide—all of which may require warnings if exposure is possible
Yes, Prop 65 may still apply even if a listed chemical is embedded or sealed inside a product. If there is a reasonably foreseeable exposure during normal use, repair, or disposal such as through handling, disassembly, or heat then a warning is required. The law focuses on exposure risk, not just chemical presence.
Safe Harbors consist of NSRLs (for carcinogens) and MADLs (for reproductive toxins). If exposure—calculated via concentration × duration × frequency × route falls below these thresholds, a warning isn't necessary. However, documentation proving this must be maintained
Prop 65 exposure requires a rigorous approach: supplier declarations must be validated via lab testing, exposure modeling, and scenario documentation. Sole reliance on declarations may miss foreseeable use-stage exposures and could lead to non-compliance
Using tools like Acquis Compliance helps automate SVHC and Prop 65 screening, risk-based exposure assessment, Safe Harbor evaluation, and automatic documentation and alerting streamlining compliance across product lines and geographies