TEYING BUYER GUIDE · UPDATED OCTOBER 1, 2026

Prop 65 vs California Metal-Containing Jewelry Law: What Jewelry Brands Must Know

Prop 65 is a warning law: attach a clear warning and the exposure obligation is addressed. The California Metal-Containing Jewelry Law is a sales law: above its lead limits, the piece cannot be sold in California at all, and a warning does not cure that. Here is where each one applies and the eight things to check on a compliance report.

By Qiu Qiu, Founder and Design Lead at TEYING · October 1, 2026

The short answer: one law lets you warn, the other stops the sale

Prop 65 obliges a business to warn before exposing consumers to a listed chemical, or to show the exposure falls below the level that triggers a warning. The California Metal-Containing Jewelry Law (Health and Safety Code sections 25214.1 to 25214.4.2) prohibits selling jewelry that exceeds its lead limits, and a warning label does not fix that. Selling into California means clearing both.

General guidance only, not legal advice as of October 2026. Confirm limits with the Department of Toxic Substances Control or counsel.

Two laws, two different obligations

The practical difference shows up in a product recall scenario. A Prop 65 claim is about whether the warning was adequate. A jewelry law violation is about whether the piece could lawfully be sold at all, and the state can assess penalties of up to $2,500 per day per violation while the piece stays on the shelf.

The limits, by product type

These are summarized from DTSC guidance. The regulations that carried the former statute into Title 27, sections 85650 to 85680, took effect without substantive change to the limits, so confirm the current text before you rely on any figure for a production decision.

Two things trip brands up. The children's category covers jewelry marketed to children six and under, not everything small and shiny, and marketing decides as much as size. And a piece can pass Prop 65 for one listed chemical while failing the jewelry law for lead, because the two laws measure different things at different thresholds.

Where the order is for children, federal rules stack on top of California's. CPSIA sets total lead limits of 100 ppm in substrate and 90 ppm in surface coatings, and children's jewelry is also tested against ASTM F2923. Put the age group in the brief, because it changes the material decision before production rather than after.

Reading a compliance report: eight checks

A test report is only useful if it answers the question the state will ask, which is whether this piece, from this production run, meets the limit. Check eight things.

1. Report number, so the certificate references a document that can be produced on request.

2. Date of issue and test date, compared against the production date of the batch you are selling.

3. Laboratory name and accreditation, so you know who stands behind the result.

4. Test method, such as EPA 3050B, 3051A, or 3052 for lead digestion, with the reporting limit stated.

5. The tested SKU, named specifically. A report for "metal alloy" without a SKU is not a report for your product.

6. Batch or lot number, tying the result to the pieces in the carton.

7. The limit value as applied, in ppm or percent, matching the California requirement for that material and age group.

8. The conclusion, with units stated and no ambiguity between ppm, mg/kg, and percent.

The failures that recur: a report that names a material but not the SKU, a report from an older production batch, a conclusion written as "pass" without a value or a limit, a lab with no accreditation, and a test run on the plating when the base alloy was the risk.

Certification flows downstream, so ask for the file

California puts the certification duty on the manufacturer or supplier, which for imported goods usually means the brand that buys them. Under the current regulations, the manufacturer or supplier must prepare a compliance certification covering the product, the standards cited, the manufacturer and laboratory details, and the test dates, provide it to sellers or display it on the packaging, and produce the technical documentation to DTSC within 28 days of a request.

A seller that received a certificate, relied on it without knowledge of the violation, and pulled the product when notified is generally shielded from penalties, unless it has been found in violation twice or more in the preceding three years. That safe harbor is why a clean, per-SKU certificate file is worth more than a single generic test report.

The penalties are worth knowing in the same breath. Civil penalties run up to $2,500 per day per violation. Falsifying a required certificate can carry a $50,000 fine, up to a year in prison, or both. Knowing and intentional violations by manufacturers or suppliers are a misdemeanor with fines from $5,000 to $100,000.

Enforcement is aimed at new, mass-produced jewelry

DTSC has said it concentrates on new, mass-produced jewelry, partly because compliance testing destroys the tested piece, which makes vintage goods impractical to test retroactively. That focus points straight at imported fashion jewelry. Online sellers are in scope: a reported DTSC action against an online bead retailer in Santa Monica ended in a $17,000 penalty, which is the pattern worth noting rather than the amount. Shipping from out of state does not move the obligation.

What to put in the order brief

• Destination market, stated per order. California sales trigger the jewelry law even when the warehouse is elsewhere.
• Age group: children six and under, or general adult.
• Body-piercing items, listed as such, because they carry their own material rules.
• Lead, cadmium, and nickel requirements up front, before production.
• Whether you need a certificate and the underlying report per SKU, and in what format.

Applicable testing and documentation are confirmed by material, destination market, and order scope, and lead-free, nickel-free, and cadmium-related requirements can be discussed before production. Requesting the report before the plating route is fixed is the difference between a test that documents a compliant piece and a test that reveals a problem.

If you are developing a collection for the US market, send the reference image, target quantity, and the age group through the TEYING quote form so the material and finish are chosen against the requirement from the start.

FAQ

Does a Prop 65 warning make jewelry legal to sell in California?

No. A warning addresses the Proposition 65 exposure obligation only. The Metal-Containing Jewelry Law independently prohibits selling jewelry above its lead limits, and no label changes that. A piece that exceeds the limit has to be reformulated or kept out of California, which is why material selection happens before production.

What are the lead limits for children's jewelry in California?

Under DTSC guidance, children's jewelry must be made entirely from permitted materials: metallic parts under 600 ppm lead, plastic and rubber under 200 ppm, surface coatings and printing inks under 600 ppm, and cadmium in components no more than 300 ppm. Children's products also meet CPSIA limits of 100 ppm total lead in substrate and 90 ppm in surface coatings.

What should a jewelry compliance report show?

Eight items: report number, test date, laboratory and accreditation, test method with reporting limit, the specific tested SKU, the batch or lot number, the limit value as applied, and a clear conclusion with units. A report missing the SKU or the batch cannot be tied to the goods you sell, which is the point DTSC will press on.

How long should I keep jewelry test reports and certificates?

Keep one file per SKU for the life of the product. DTSC can request technical documentation within 28 days, and the retailer safe harbor depends on having a certificate you relied on and can produce. Files age out of usefulness when the material, plating route, or supplier changes, so a new report goes with a new specification.