Proposition 65 and Wet vs. Dry Paints and Glues


If a product such as paint is not compliant with Proposition 65 before it is used, but becomes compliant once it has been applied and cured or baked on by the original equipment manufacturers (OEMs) that purchase it, is it necessary to label for Proposition 65? If so, is it necessary to report on its status before or after it has been applied?


Many materials, including paints, coatings, adhesives and epoxies, can have a different Proposition 65 compliance status when sourced uncured from a vendor versus as a cured finished product. Unless coating pigments use heavy metals, cured or baked on coatings will not likely require Proposition 65 warnings.

Article current as of 2019-12-06.

See also: Proposition 65 and Branded Labels

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