By Hitesh Ram | Fri Jun 6 2025 | 2 min read

Table of Contents

What Are Safe Harbor Levels?

Safe harbor levels under Ca Prop 65 are thresholds below which no warning is legally required. These include:

  • No Significant Risk Levels (NSRLs) for carcinogens
  • Maximum Allowable Dose Levels (MADLs) for reproductive toxins

If your product’s exposure falls below these levels, you’re safe from enforcement—but you must prove it.

How Exposure Works in Electronics Products

Prop 65 regulates exposure, not just content.

This means:

> Even if a chemical is present in a product, it does not trigger a warning unless the user is likely to be exposed.

For electronics, this exposure might occur via:

  • Touch (e.g., cables with DEHP)
  • Inhalation (e.g., off-gassing adhesives)
  • Wear or degradation (e.g., plastic casings or connectors)

Calculating Risk: Intake, Exposure, and Use Cases

Exposure is calculated as:

> Exposure = Concentration × Duration × Frequency × Route

You must factor in:

  • Product use scenarios (daily use vs. industrial assembly)
  • Vulnerable populations (e.g., children, pregnant workers)
  • Transferability (does the chemical leach or volatilize?)

This is often modeled using tools like:

  • Exposure estimation software
  • Toxicology databases
  • OEHHA risk equations

Common Safe Harbor Levels for Electronics-Relevant Chemicals

Here are Prop 65 thresholds often triggered in electronics products:

CA PROP 65 Common Safe Harbor Levels for Electronics-Relevant Chemicals.PNG

Even if these substances are present, you don’t need a warning if exposure stays under these levels.

When to Issue a Prop 65 Warning

If exposure to a listed chemical exceeds the safe harbor level, you must issue a clear and compliant warning.

Key considerations:

  • Use the standard Prop 65 warning language
  • Indicate the chemical name and risk type
  • Ensure the label is visible at the point of purchase or use
  • If you're not sure—warn or conduct a risk assessment

Remember: Many brands warn preemptively to avoid litigation, especially in ambiguous cases.

Automating Risk Assessments with Regilient

Regilient enables brands to:

  • Track chemical content across the supply chain
  • Calculate exposure using usage scenario models
  • Flag materials that approach or exceed safe harbor limits
  • Generate pre-formatted warning labels automatically

Request a Demo →

Don’t risk it — assess it. If you're unsure whether your electronics product requires a Prop 65 warning, Regilient helps you automate risk assessments based on safe harbor thresholds.

Book Your Prop 65 Risk Review

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Safe Harbor Levels in Prop 65: What Electronics Brands Need to Know

What exactly are “safe harbor levels” under Prop 65?
Safe harbor levels are exposure thresholds set by California’s OEHHA where no Prop 65 warning is required. They include: NSRLs (No Significant Risk Levels) for carcinogens MADLs (Maximum Allowable Dose Levels) for reproductive toxins If exposure remains at or under these limits, you have a legal “safe harbor” against warnings or enforcement
How do safe harbor levels differ from chemical concentration in a product?
Safe harbor levels are based on daily exposure in µg/day (e.g., breathing, skin contact, ingestion)—not the chemical’s % by weight in a product. Exposure assessment must consider use frequency, duration, and route
How many Prop 65 chemicals have OEHHA-defined safe harbor levels?
OEHHA has published safe harbor levels for over 300 chemicals , and continues to add more each year
Do electronics need Prop 65 warnings if chemicals are present?
Presence alone isn’t enough. You only need a warning if user exposure exceeds the safe harbor level , determined through use-case modeling (e.g., touching cables, inhaling fumes, component wear)
How do brands calculate exposure for electronics?
Exposure is calculated as: Concentration × Duration × Frequency × Route . Many electronics brands use toxicology models , exposure estimation tools, and OBAs (occupational biology assumptions) to evaluate if exposure stays below NSRL/MADL
What if no safe harbor level exists for a specific chemical?
If OEHHA hasn’t published a safe harbor level, you must still conduct your own exposure assessment or provide a warning. OEHHA regulations outline standardized methods for this case
Is overwarning a concern with Prop 65?
Yes. Many brands implement warnings even when exposures are minimal or below safe harbor levels due to enforcement risk. However, relying on scientific exposure assessments can help reduce unnecessary warnings while maintaining legal defense