Prop 65

Prop 65 Compliance for Online Stores

California's bounty-hunter statute lets private attorneys sue any seller that ships to the state without proper chemical warnings — and e-commerce is the easiest target.

800+Prop 65 filings in 2024 alone
Prop 65 — Chemical Scanner
Chemical Analysis
3 products scanned
Detected Chemicals — Collagen Gummies
Lead (Pb)
0.8 µg/serving · Limit: 0.5 µg/day
Exceeds
Cadmium (Cd)
0.3 µg/serving · Limit: 4.1 µg/day
Pass
Arsenic (As)
Trace · Limit: 10 µg/day
Trace
Product Scan Results
Collagen Gummies
/collagen-gummies
Daily Multivitamin
/daily-multi
Protein Powder
/whey-protein
Auto-Generated Warning

⚠ WARNING: This product can expose you to chemicals including Lead, which is known to the State of California to cause cancer and birth defects or other reproductive harm.

What is this and why should you care?

Proposition 65 is a California law that requires businesses to provide warnings when exposing consumers to chemicals known to cause cancer or reproductive harm. The list includes over 900 chemicals — everything from lead and cadmium to common compounds found in everyday consumer products.

For e-commerce sellers, Prop 65 means that if your product contains any listed substance above a safe-harbor threshold and you ship to California, you must display a clear and reasonable warning before the point of purchase. Not just on the box — on the product page itself.

The law is enforced almost entirely by private attorneys (not the state). It allows anyone to file suit, collect penalties of up to $2,500 per day per violation, and recover attorney fees. This has created a cottage industry of 'bounty hunter' law firms that systematically target online stores.

Cal. Health & Safety Code §25249.6Prop 65 (1986)
Plaintiff Playbook

How they find and target online stores

Plaintiff firms have industrialized this process. Here is exactly how they find and target online stores:

01
Step 01

Buy & Test

The firm purchases products from your store, often creating test accounts with California shipping addresses. They send items to a lab to check for listed chemicals like lead, cadmium, or DEHP.

02
Step 02

Document the Gap

They screenshot your product pages, checkout flow, and confirmation emails — building a record that no Prop 65 warning was displayed before purchase.

03
Step 03

File 60-Day Notice

California law requires a 60-day notice before filing suit. This notice goes to you and the California Attorney General. Most stores settle during this window.

04
Step 04

Sue or Settle

If you don't settle in 60 days, they file in California Superior Court. Penalties run $2,500 per day per violation, plus attorney fees — which is the real profit center.

60-day notice period, then lawsuit filed

Don't wait for the demand letter.

SuitProof scans your store for these exact vulnerabilities before attorneys do.

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Real Cases

What it actually costs

$45,0002023

DiCenzo v. Amazon Sellers (2023)

Multiple third-party Amazon and Shopify sellers hit with Prop 65 notices for jewelry containing lead above safe harbor levels with no online warnings.

$65,0002024

CERT v. Supplement Brand (2024)

Health supplement DTC brand settled after lab tests found listed chemicals in protein powder. No Prop 65 warnings on product pages or at checkout.

$32,0002023

Mateel v. Cosmetics Retailer (2023)

E-commerce cosmetics brand sued for lead content in lipstick products. Settlement included reformulation commitment plus warnings.

$28,0002024

EHA v. Home Goods Store (2024)

Online home goods seller targeted for DEHP in vinyl products. Settled after discovery showed zero compliance measures in place.

Prevention costs less than a settlement.

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Risk Checklist

Are you at risk?

If you answer yes to any of these, you may be at risk of a Prop 65 demand letter:

You ship products to California customerscritical
Products contain metals, chemicals, or compounds on the Prop 65 listcritical
No Prop 65 warning appears on product pagescritical
No Prop 65 warning appears during checkouthigh
Product packaging has warnings but your website does nothigh
You sell supplements, cosmetics, jewelry, or electronicsmedium
Your Prop 65 warning text doesn't match current safe-harbor languagemedium

Find out before they do.

SuitProof automatically scans your Shopify store for these exact risks. Get on the waitlist for early access and a free compliance scan.

SuitProof

How SuitProof catches this

Warning Detection

Scans every product page for Prop 65 warning language and verifies it meets safe-harbor formatting requirements.

Checkout Flow Audit

Checks your cart and checkout pages for required pre-purchase warnings that many stores miss.

Case Law Intelligence

Tracks active Prop 65 filings and identifies which product categories and firms are being targeted right now.

Label Compliance

Verifies your online warning language matches the latest safe-harbor requirements and AG guidance.

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Your next product launch deserves full coverage

Most compliance gaps are quick fixes — the hard part is knowing they exist. Run your first scan in five minutes and launch with confidence.