California Proposition 65 and small kitchen appliances: when it does not apply, and when it does

Compliance · 2026-10-16

The published figures

The four material questions, and why the product-level answer is not enough

Our espresso machines do not use a brass boiler component, and we publish no brass boiler specification. This table lists the component types importers most often ask about in general — it is not a statement about our products.

How the regime actually works

Prop 65 operates by listing chemicals and, for some listings, levels at which exposure requires a warning. Businesses are required to provide a warning when their product causes exposure above the relevant level, subject to the specific exemptions and safe-harbour provisions in the regulation.

Two consequences follow for an importer. First, there is no compliance certificate to obtain and no listing on a supplier document that settles the question — the analysis is per material and per component. Second, a supplier stating "Prop 65 compliant" has not given you something you can file, because the compliance is a function of the finished product's composition, not of a certificate held by the factory.

What actually reaches a small appliance

For small kitchen appliances, the components that most often draw attention are not the ones buyers expect. They are the brass or copper alloys in fittings and brazing joints, the lead content in solders, certain pigments and colourants in plastics and coatings, and the surface treatments on metal parts.

Notice that all four are material questions. None of them is a product-category question. This is why a supplier who answers a Prop 65 question at the product level rather than the material level has not really answered it.

How to get a question you can act on

Replace "is this product Prop 65 compliant" with four narrower questions that can actually be answered:

Which listed chemicals does the supplier expect to be relevant to this product? A supplier with real material data will name them. One without will say "fully compliant".

What is the declaration basis for each material? Supplier declaration, third-party laboratory test, or a purchased material's own declaration that is then relabelled.

Does it cover the components sourced from sub-suppliers? The purchased-material route is where a small appliance's exposure usually sits, and it is the part that gets skipped.

What changes if a component is substituted? A material change is a Prop 65 event as much as a quality event.

What we publish, and the honest limit of it

Our published marks include RoHS and REACH, both named by our corporate site and our Global Sources profile. RoHS restricts hazardous substances in electrical equipment and REACH is the EU chemicals framework including SVHC declaration. Neither of them is a Proposition 65 analysis, and we do not present them as one.

For a US-bound programme, ask us for the material documentation behind the components in the specific model. If the answer requires a per-chemical assessment that neither of our published channels covers, we will say that rather than offer a conclusion.

What to do if you are not sure which case you are in

Treat it as unresolved rather than assumed-clear. Ask the supplier the four material questions above in writing, and keep the answers with your specification file. If the answer requires an exposure assessment for your specific finished product and destination, that is a specialist question rather than a factory question.

What we will say if you ask us

We will tell you which of our published marks relate to chemical restriction — RoHS and REACH — and what each of those does and does not cover. We will not present either as a Proposition 65 conclusion, and we will not quote a Proposition 65 limit value on this page.

Where the figures behind this came from

Every number on this page traces to one of these.

Models this guide applies to

Grills & Baking

Primary line. Seasonal shape, pairs with pizza makers and air fryers.

Coffee Makers

Primary line. Parts-intensive, so the spares plan is designed with the product.

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