What Proposition 65 does
California Proposition 65 requires warnings where products expose people in California to listed chemicals. The list is maintained by the state and is long. The law does not ban the chemicals; it requires a clear and reasonable warning where an exposure occurs, unless an exemption applies. Many brands and retailers prefer to manage their materials so that a warning is not needed, rather than putting warnings on apparel.
This note is general information to help you plan. It is not legal advice. The rules on when a warning is required, its wording and its placement are specific, and the chemical list changes. Confirm the current requirements with a compliance adviser.
Why it matters to activewear sellers
Activewear sold online reaches California customers whether or not the brand targets them. Wholesale partners and marketplaces often ask suppliers to confirm compliance or to state whether a warning is required. A brand that cannot answer clearly can lose a listing or a wholesale account, even if the product itself is fine.
Because yoga apparel is worn against the skin for long periods, buyers tend to focus questions on materials in direct contact with the body and on parts that are handled often, such as zipper pulls and drawcord ends.
Where to look in a yoga garment
The base knit fabric is only one part of a garment. In practice, the components that draw the most questions are often small ones.
| Component | Why buyers ask about it | Typical document |
|---|---|---|
| Dyed main fabric | Dyes and finishing chemicals are applied at the mill | Mill declaration, any harmful-substance certificate for that fabric |
| Logo prints and heat transfers | Print and transfer chemistry varies; plastic-based prints draw questions about substances such as phthalates | Print or transfer supplier declaration |
| Silicone logos and grippers | Coated and rubber-like components | Supplier declaration |
| Metal trims: zip pulls, eyelets, aglets | Metal components draw questions about substances such as lead | Trim supplier declaration, test report where advised |
| Plastic trims and drawcord ends | Plastics and coatings | Trim supplier declaration |
| Bra pads and foam | Foams and their treatments | Pad supplier declaration |
The point of the table is not that these components contain listed chemicals. It is that each one comes from a different supplier, and each needs its own answer.
A component-based approach
- Build a material list for each style: main fabric, lining, elastic, thread, prints, transfers, trims, pads and packaging that touches the product.
- Identify the supplier of each component, including trims bought by the factory from its own vendors.
- Request declarations from each supplier on the listed chemicals of concern for that component type, as agreed with your adviser.
- Decide on testing with your adviser, prioritizing components most likely to raise questions, such as prints and metal or plastic trims.
- Decide on warnings or substitution. Where a component may cause an exposure, decide whether to change it or to provide a warning in the required form.
- Lock the bill of materials so that trims cannot be swapped without your approval.
Logos and prints deserve extra attention
Logo methods differ in their chemistry: heat transfers, silicone logos, screen prints, sublimation and woven labels all use different materials. When you choose a logo method, ask the supplier for the declaration at the same time you ask for a sample. Changing a logo method after launch is more expensive than choosing a documented one at the start. The logo methods note compares the options in feel and durability.
Overlap with other requirements
Several requirements touch the same materials. CPSIA sets a total lead content limit of 100 ppm and phthalate limits for children's products, with third-party testing. PFAS rules, such as California AB 1817 for intentionally added PFAS in textile articles from 2025, address another chemical family. Harmful-substance certifications such as OEKO-TEX STANDARD 100 may support your documentation, but whether they answer a specific Proposition 65 question should be confirmed with your adviser. Organizing documents by component lets one material list serve all of these requests. Read PFAS-free activewear for the PFAS side.
Working with wholesale and online partners
Retail partners often send a compliance questionnaire before listing a product. Keep a short summary per style: components, suppliers, declarations received, any testing done and the decision on warnings. If a partner asks about a specific delivery, you should be able to show documents for that delivery's materials.
When you add a new color or style, the work is incremental. Most components carry over, and only the new fabric color, print or trim needs a new declaration.
Keeping the file current
Declarations age. Suppliers change their own raw material sources, mills adjust dye recipes, and the state list of chemicals is updated from time to time. A file that was complete for the first order can be out of date by the third. A simple routine helps: review the component list at each reorder, ask suppliers to confirm that nothing has changed for the materials in that order, and ask your adviser at regular intervals whether list changes affect any component you use. Note the date of each declaration in your summary so it is obvious which documents need refreshing.
This routine also protects you when a wholesale partner sends an updated questionnaire. Instead of starting from scratch, you are confirming a file that is already organized by style and component.
Private label considerations
For private label programs, the brand owner is the one facing the customer and the retail partner. Even when the factory supplies most components, keep the declarations in your own files. The private label page explains how a program is set up, including which documents the brand receives.
How we help
We build the component list with the partner factory, collect supplier declarations and flag components where information is missing. We check at pre-production that the approved trims and prints are the ones being used. We do not give legal advice or decide warnings for you, and we do not describe any supplier as certified unless a certificate is verified for that scope. Our compliance page lists the documents we gather, and the quality control page shows where trim checks sit. To include this from the first sample, send the desk your styles and trim list.