Prop 65 on TikTok Shop: California Warning Requirements

Quick Definition

Prop 65 (officially the Safe Drinking Water and Toxic Enforcement Act of 1986) is a California law requiring businesses to warn consumers about significant exposures to chemicals that cause cancer, birth defects, or reproductive harm. On TikTok Shop, products sold to California customers must include proper Prop 65 warnings or risk policy violations and violation points.

Scope: Prop 65 applies to ALL products sold to California residents, regardless of where the seller is located.

Related: Prop 65 compliance is part of overall compliance alongside CPSC requirements and avoiding prohibited keywords.

Understanding Prop 65

What Prop 65 Requires

Businesses must:

Identify if products contain listed chemicals above threshold levels
Provide warnings that are "clear and reasonable"
Display warnings before purchase (on TikTok = in listing)

The Chemical List

Prop 65 covers 900+ chemicals, including:

Category	Common Chemicals
Heavy metals	Lead, cadmium, mercury, arsenic
Solvents	Benzene, formaldehyde, toluene
Pesticides	Various agricultural chemicals
Industrial	Phthalates, BPA, certain dyes
Natural	Acrylamide (in cooked foods), wood dust

Full list: California OEHHA website maintains the complete list.

Who Needs to Comply

If you:

Sell products that ship to California
Have products containing Prop 65 chemicals
Have 10+ employees (some exemptions for smaller businesses)

Then Prop 65 likely applies to you.

Prop 65 on TikTok Shop

TikTok's Requirements

TikTok Shop enforces Prop 65 as part of seller compliance:

Requirement	TikTok Enforcement
Warning present for applicable products	Yes
Warning in product listing	Yes
Warning meets legal requirements	Yes
False warnings (unnecessary)	May be flagged

Consequences of Non-Compliance

Issue	Consequence
Missing required warning	Listing suspension + 4-8 points
Inadequate warning	Listing suspension + 2-4 points
Pattern of missing warnings	Account scrutiny

Beyond TikTok: Private lawsuits can result in $2,500+ per violation per day.

Products That Typically Require Warnings

High-Risk Categories

Category	Common Chemicals	Warning Usually Needed
Electronics	Lead (solder, cables)	Yes
Jewelry	Lead, cadmium	Yes
Handbags/accessories	Lead (zippers, hardware)	Yes
Candles	Soot, certain fragrances	Often
Supplements	Varies by ingredient	Sometimes
Cosmetics	Certain ingredients	Sometimes
Cookware	PTFE (non-stick), aluminum	Sometimes
Toys	Lead, phthalates	Yes
Furniture	Formaldehyde, wood dust	Yes
Apparel	Certain dyes, flame retardants	Sometimes

Products That May Not Need Warnings

Food (covered by FDA, mostly exempt)
Products with no listed chemicals
Products below threshold levels (with testing)
Products sold only outside California

The Warning Requirements

Standard Warning Format

For cancer-causing chemicals:

⚠️ WARNING: This product can expose you to chemicals including
[chemical name], which is known to the State of California to
cause cancer. For more information go to www.P65Warnings.ca.gov.

For reproductive harm chemicals:

⚠️ WARNING: This product can expose you to chemicals including
[chemical name], which is known to the State of California to
cause birth defects or other reproductive harm. For more
information go to www.P65Warnings.ca.gov.

For both:

⚠️ WARNING: This product can expose you to chemicals including
[chemical name], which is known to the State of California to
cause cancer and birth defects or other reproductive harm. For
more information go to www.P65Warnings.ca.gov.

Short-Form Warning

For space-limited situations (may be acceptable on TikTok):

⚠️ WARNING: Cancer and Reproductive Harm - www.P65Warnings.ca.gov

Warning Symbol

The warning must include or be preceded by:

A warning symbol (⚠️ triangle)
The word "WARNING" in bold or caps

How to Add Prop 65 Warnings on TikTok

In Product Description

Include at the beginning or end of your description:

CALIFORNIA PROP 65 WARNING: ⚠️ This product can expose you to
chemicals known to the State of California to cause cancer and
birth defects or other reproductive harm. For more information
go to www.P65Warnings.ca.gov

In Product Images

Some sellers add warning text to product images:

┌─────────────────────────────────────┐
│         Product Image               │
│                                     │
│                                     │
├─────────────────────────────────────┤
│ ⚠️ CA Prop 65 Warning: See listing │
└─────────────────────────────────────┘

Placement Best Practices

Location	Effectiveness	Notes
Top of description	High visibility	Recommended
End of description	Less visible	Acceptable
Separate section	Clear	Good for organization
Image only	Risky	Should be in text too

Determining If You Need a Warning

Option 1: Assume and Warn

Many sellers add warnings to all products as a precaution:

Pros:

Safe from lawsuits
No testing needed
TikTok won't flag for missing warning

Cons:

Over-warning may concern customers
May be unnecessary

Option 2: Test Your Products

Get products tested for Prop 65 chemicals:

Testing costs: $200-2,000+ per product

Pros:

Know exactly what's in your product
Only warn when necessary
Better customer confidence

Cons:

Expensive
Time-consuming
May still need warnings

Option 3: Supplier Documentation

Request compliance documentation from suppliers:

Document	What It Proves
Certificate of Compliance	Supplier's Prop 65 status
Test reports	Chemical levels
Material safety data sheets	Ingredient information

Common Mistakes

1. Assuming Products Are Exempt

Many products contain Prop 65 chemicals unexpectedly:

Metal zippers and buttons contain lead
Wood products contain wood dust
Electronics contain lead solder

2. Generic Warnings

Using warnings that don't meet legal requirements:

Missing chemical names (when required)
Missing warning symbol
Missing website reference

3. Warning in Wrong Location

The warning must be visible before purchase:

On the listing (not just in the package)
Easily findable (not buried)
Readable (adequate size)

4. Ignoring California

"We don't ship to California" isn't a complete solution:

Customers may use forwarding services
TikTok delivers to all US addresses
May still face legal exposure

Safe Harbor Warnings

California provides "safe harbor" language that, if used correctly, protects against lawsuits:

Benefits of Safe Harbor

Pre-approved language
Legal protection
Clear compliance

Requirements

Use exact approved language
Include chemical name when required
Include proper symbol and website
Place warning appropriately

Key Takeaways

Prop 65 applies to California sales — All TikTok US sellers affected
900+ chemicals listed — Many common materials included
Warnings must be in listing — Not just on product/packaging
Missing warnings = violations — Points and suspensions
When in doubt, warn — Over-warning is safer than under-warning
Use proper format — Symbol, WARNING, website required

Related Resources

Ensure Prop 65 Compliance with ShopGuard

ShopGuard helps you stay Prop 65 compliant:

Detection — Identifies products likely needing warnings
Template warnings — Pre-formatted compliant language
Audit — Check all listings for missing warnings
Category guidance — Know which products need warnings

Get compliant now →