Proposition 65, Catalogs, and Printed Material

Question: One of my company's suppliers does not provide us with product components, but instead prints product catalogs for us. Because these are literature rather than products, are they in scope of the Safe Drinking Water and Toxic Enforcement Act (California Proposition 65)? Are there any listed substances that might be present in a catalog?

Answer: Catalogs and marketing literature, along with other free items such as prizes in trade show giveaways or product storage cases, are generally still in scope of regulations such as Proposition 65. 

Considering the specific composition of catalogs and literature, some at-risk substances may include:

  • Heavy metals, such as lead or cadmium, which may be used as pigments in printing inks.
  • Phthalate plasticizers, which may be used in flexible plastic "paper" or adhesive labels/stickers.

Disposable packaging shipped with a product but not intended to be retained by the consumer, however, is out of scope of Proposition 65 except in the case of manufacturers/distributors of the packaging itself.

 

This article is current as of May 5, 2021.

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