California Proposition 65 Inspection Process for Electronic Components
Date：2025-12-09 09:41:56 Classification
：【question】 Visits：
The California Proposition 65 testing process for electronic components is indeed a crucial compliance step that must be clarified before a product enters the California market. Based on your industry background, the testing process for electronic components can be summarized into four core stages: "Defining the Scope → Professional Commissioning → Precise Testing → Compliant Output." Each step has technical details that require special attention.
Step 1: Defining the Testing Scope and Exemption Conditions
Testing of electronic components should focus on "accessible parts," that is, parts that users may touch during normal use (such as casings, buttons, interfaces, cable sheaths, etc.), rather than non-accessible parts such as internally packaged chips.
- Key Exemption: If internal components have already passed RoHS certification, a partial exemption can be applied for (a RoHS report is required).
- Examples of Required Tested Components: Power adapter casing, USB data cable sheath, earphone silicone sleeve, charger plug metal contacts, etc.
Step 2: Preparing Core Documents and Samples
Two key documents need to be prepared in advance to ensure the testing agency can accurately locate the test points:
1. Technical Documents
- Product manual (indicating material type, such as ABS plastic, PVC cable, etc.)
- Complete BOM (Bill of Materials), specifying the material composition of each accessible component
- Manufacturing process description (e.g., whether coating, electroplating, etc., are used)
2. Test Samples
- Quantity: 2-3 complete sets of samples (including all accessible components)
- Special Requirements: If the product has multiple color or material versions (e.g., black/white casing), separate samples must be provided for each.
Step 3: Selecting a Laboratory and Determining Testing Items
1. Laboratory Qualifications
- Prioritize agencies with CNAS/CMA accreditation and recognized by the California OEHHA (Office of Environmental Health Hazard Assessment) (e.g., Dezeway Testing, CNAS registration number: L8083).
2. High-Frequency Testing Items for Electronic Components
| Substance Category | Typical Limits | Examples of Components Involved
| Total Lead (Pb) | ≤100ppm (non-coated materials) | Metal interfaces, solder joints, plastic casings
| Total Cadmium (Cd) | ≤300ppm (battery components) | Lithium battery casings, electroplated parts
| Phthalate | ≤0.1% (1000ppm) per type | PVC cables, soft plastic buttons
| Bisphenol A (BPA) | ≤1000ppm | Polycarbonate (PC) casings
Step 4: Testing Procedure and Cycle
1. Standard Procedure
- Consultation and Quotation: After providing the BOM, the agency will provide a quotation based on the complexity of the materials (approximately 500-1000 RMB per item for testing).
- Sample Submission and Testing: After the sample arrives, the laboratory will use equipment such as ICP-MS (heavy metals) and GC-MS (phthalates) for testing.
- Report Issuance: Standard processing time is 5-7 business days; expedited processing can be shortened to 3 days. The report must include the testing method, limit comparison, and compliance conclusions.
2. Handling Special Cases
- If the test results exceed the limit: The material must be rectified (e.g., replaced with low-lead paint) and resubmitted for testing, or a California Proposition 65 warning label must be affixed to the product/packaging (the format must comply with regulations, such as "WARNING: This product contains lead, a known carcinogen in California").
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