HTSBase
Prop 65CaliforniaPhone cases

Do phone cases need a Prop 65 warning?

Updated

Short answer

Often no for TPU or polycarbonate cases that test clean. Possibly yes for soft PVC or metal parts.

A phone case is handled for hours a day, so Prop 65 turns on what the materials can transfer to skin and hands. Common TPU, silicone and polycarbonate cases often need no warning if tests show no listed chemical at levels that create an exposure above safe harbor. Soft PVC with DEHP or other listed phthalates, BPA in some polycarbonate, and lead or nickel in metal frames, rings and kickstands are where warnings come from. Businesses with fewer than 10 employees are exempt.

What changes the answer

  • Material by part. Test each accessible part: the shell, bumper, printed or glitter layer, metal ring or stand, and any lanyard or strap. One PVC strap can drive the warning for the whole product.
  • BPA. BPA is listed for female reproductive and developmental toxicity. Polycarbonate is made from BPA, and residual BPA can be present. The question is exposure through handling, which requires testing of the actual case.
  • Phthalates. DEHP, DINP, DBP and BBP are listed. TPU and silicone are not normally plasticized with phthalates, but colorants and recycled content can introduce them.
  • Online sellers. For internet sales, the warning must be on the product page, behind a link labeled "WARNING", "CA WARNING" or "CALIFORNIA WARNING", or shown before the purchase is complete (27 CCR 25602(b)), in addition to any label.
  • Responsibility. The manufacturer, importer or distributor is primarily responsible. A retailer is liable mainly for its own brands, products it altered, or warning materials it received and did not post.

What to do

  1. Get material declarations for every component and test the finished case for listed phthalates, BPA and, for metal parts, lead and nickel.
  2. Compare results with safe harbor levels or a documented exposure assessment.
  3. If a warning is required, use the 27 CCR 25603 content naming a chemical for each endpoint, with the triangle symbol. A short-form label must name a chemical; legacy short forms are protected only for products made and labeled before January 1, 2028.
  4. Send written notice and warning materials to your retailers and renew it each year under 25600.2.
HTS lines used for phone cases
  • 4202.32.20.00

    4202: Trunks, suitcases, vanity cases, attache cases, briefcases, school satchels, spectacle cases, binocular cases, camera cases, musical instrument cases, gun cases, holsters and similar containers; traveling bags, insulated food or beverage bags, toiletry bags, knapsacks and backpacks, handbags, shopping bags, wallets, purses, map cases, cigarette cases, tobacco pouches, tool bags, sports bags, bottle cases, jewelry boxes, powder cases, cutlery cases and similar containers, of leather or of composition leather, of sheeting of plastics, of textile materials, of vulcanized fiber or of paperboard, or wholly or mainly covered with such materials or with paper

    Articles of a kind normally carried in the pocket or in the handbag / With outer surface of sheeting of plastics or of textile materials / With outer surface of sheeting of plastics / Other

    Articles normally carried in the pocket or handbag, with outer surface of plastic sheeting. Some soft cases are entered here.

    General rate
    20%
    Free or reduced under 17 programs
  • 4202.99.10.00

    4202: Trunks, suitcases, vanity cases, attache cases, briefcases, school satchels, spectacle cases, binocular cases, camera cases, musical instrument cases, gun cases, holsters and similar containers; traveling bags, insulated food or beverage bags, toiletry bags, knapsacks and backpacks, handbags, shopping bags, wallets, purses, map cases, cigarette cases, tobacco pouches, tool bags, sports bags, bottle cases, jewelry boxes, powder cases, cutlery cases and similar containers, of leather or of composition leather, of sheeting of plastics, of textile materials, of vulcanized fiber or of paperboard, or wholly or mainly covered with such materials or with paper

    Of plastics

    Other cases and containers of plastics, other than sheeting. Molded cases may fall here; check CBP rulings.

    General rate
    3.4%
    Free or reduced under 17 programs

Next steps

Frequently asked questions

Does a silicone phone case need a Prop 65 warning?
Usually not because of the silicone, but pigments, coatings and metal parts can contain listed chemicals. Test the finished case to know.
Is a Prop 65 warning required for sales outside California?
No. Prop 65 applies to exposures in California. If you sell nationwide on one listing, the online warning has to reach California buyers, so many sellers show it to everyone.
Can a warning protect me if my case also fails a legal limit?
No. A warning addresses Prop 65 only. Product limits in other laws, such as federal lead limits for children's products, still apply.

Sources

  1. Proposition 65 in Plain Language, California OEHHA
  2. Proposition 65 regulations, 27 CCR 25600 to 25607 (warnings), California OEHHA
  3. List of Proposition 65 chemicals, California OEHHA

This is general information drawn from the official sources linked above. It is not legal advice. Rules change and often turn on the facts of your product, so confirm your test plan with an accredited lab and your obligations with qualified counsel before you import or sell.