Supplier Declaration

A supplier declaration (also called a material declaration or substance declaration) in the Proposition 65 context is a written statement from a component or material supplier confirming the chemical content of supplied materials relative to Proposition 65-listed substances. Unlike EU RoHS (which has standardised material declaration requirements under EN IEC 63000:2018), Proposition 65 has no standardised mandatory declaration format. However, supplier declarations are a critical component of a manufacturer’s Proposition 65 compliance programme, providing the primary evidence base for determining whether products contain listed chemicals at exposure-triggering concentrations.

No official Proposition 65 format for supplier declarations; interpreted based on OEHHA Proposition 65 compliance requirements; Cal. Health & Safety Code §25249.6.

Manufacturers and importers should establish a systematic supplier declaration programme for all components and materials used in California-market products. Declarations should: identify all Proposition 65-listed chemicals present in materials; state their concentrations; and confirm whether concentrations are above or below relevant safe harbour levels. For electronics, the IPC-1752A material declaration format (widely used for REACH and RoHS) can be adapted to include Prop 65 substance information. When supplier declarations are unavailable, testing by accredited laboratories is required.