Case Study: Resolving Proposition 65 Compliance Risk Without Delaying Distribution

Industry

Apparel & Consumer Products Manufacturing

Application

Garments and textile products sold and shipped into California

Challenge

Proposition 65 compliance risk and labeling uncertainty

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Background

A U.S.-based manufacturer selling apparel nationwide identified a potential Proposition 65 (Prop 65) compliance risk related to products distributed into California. While the garments were already in production, the company lacked a permanent, compliant warning label solution suitable for sewn apparel.

Given California’s strict enforcement environment, the manufacturer needed to address the issue quickly—without disrupting production schedules or distribution timelines.

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The Challenge

During internal compliance review, the manufacturer identified several concerns:

• Products sold into California required Prop 65 warnings
• Existing solutions relied on temporary hang tags or packaging labels
• There was uncertainty around label permanence and placement
• Production timelines allowed little margin for relabeling or rework

Failure to address the issue could have resulted in:

• Compliance exposure under California Prop 65
• Distribution delays
• Costly relabeling or product holds

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Evaluation Process

The manufacturer worked with a labeling supplier to evaluate compliant solutions that would:

• Meet California Prop 65 warning requirements
• Be suitable for sewn apparel applications
• Remain permanent and legible throughout the product lifecycle
• Integrate into existing production workflows
• Be scalable for future production runs

Multiple options were reviewed, including adhesive labels, hang tags, and sewn-in warning labels.

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Solution

To minimize risk and ensure long-term compliance, the manufacturer implemented a sew-in Prop 65 warning label solution.

Key elements of the solution included:

• Permanent sewn-in labels instead of removable tags
• Clear Prop 65 warning language with required signal word and URL
• Durable label materials designed to withstand washing and wear
• Placement integrated into garment construction
• Bulk production aligned with manufacturing schedules

This approach ensured warnings remained attached to the product at the point of sale and throughout consumer use.

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Results

The manufacturer was able to:

• Address Prop 65 compliance requirements without delaying production
• Reduce reliance on temporary or removable warnings
• Lower long-term compliance risk for California distribution
• Establish a repeatable labeling solution for future product lines

By resolving the issue proactively, the company avoided potential enforcement exposure and protected its distribution pipeline.

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Key Takeaways

• Prop 65 compliance applies to products sold or shipped into California, regardless of manufacturer location
• Temporary warnings may not be sufficient for sewn apparel
• Permanent, sewn-in warning labels reduce compliance risk
• Early evaluation prevents costly relabeling and distribution delays
• Scalable labeling solutions support long-term compliance strategies

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Supplier Capabilities

Lee Label provides sew-in Proposition 65 warning labels for apparel and textile manufacturers. With U.S. and overseas production capabilities, Lee Label supports volumes from 5,000 to 500,000+ units, offering durable, compliance-ready labeling solutions designed for integration into garment manufacturing.