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AGT Labs Food Testing

California Prop 65 Testing
Compliance Analysis

Protect your brand from lawsuits with our accredited California Prop 65 testing services. Specifically, we provide ultra-low level detection of Lead, Cadmium, Arsenic, and Mercury to ensure compliance with California's Safe Harbor limits.

Accreditation
ISO/IEC 17025:2017 · Cert L26-535
Method
AOAC 2015.01 · ICP-MS
Target Analytes
Lead, Cadmium, Arsenic, Mercury

Navigate Regulations with Prop 65 Compliance Screening

California Proposition 65 (The Safe Drinking Water and Toxic Enforcement Act) is one of the strictest chemical regulations in the world. Specifically, it requires businesses to provide a Clear and Reasonable Warning if their product exposes consumers to chemicals known to cause cancer or reproductive toxicity.

Why Heavy Metals Are the Primary Risk for Food Brands

For food manufacturers, the primary risk involves naturally occurring heavy metals a subset of our broader chemical contaminant testing. Unfortunately, a simple "Pass" from an FDA perspective may still fail Safe Harbor limits, and as a result, this can lead to expensive lawsuits. Therefore, you should also ensure your nutrition facts labels are compliant alongside any Prop 65 warnings. Ultimately, AGT Food Labs delivers the precise, low-level California Prop 65 testing needed to determine whether your product requires a warning label before it ships into the California market.

The California Prop 65 Testing Process

From sample submission to exposure calculation, we guide you through compliance.

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01. Request
First, request a Prop 65 screen and provide your product's Daily Serving Size (crucial for the exposure calculation).
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02. Shipping
Next, send approximately 100 g of sample to our lab (contact us to confirm the exact quantity). For robust California Prop 65 testing, we recommend submitting 3 distinct production lots to account for variability.
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03. ICP-MS Analysis
Then, we use Inductively Coupled Plasma Mass Spectrometry (ICP-MS) per AOAC 2015.01 (SOP 046) to detect metals at parts-per-billion levels.
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04. Exposure Report
Finally, we convert the results into micrograms/day exposure and compare against the Prop 65 Safe Harbor thresholds MADL (Maximum Allowable Dose Level for reproductive toxicity) and NSRL (No Significant Risk Level for cancer).

California Prop 65 Testing Services

Specialized screening designed to detect "The Big 4" heavy metals at trace levels.

ICP-MS instrument used for California Prop 65 testing of heavy metals
The Big 4

Heavy Metals Screen for Prop 65

We test for the four heavy metals most commonly cited in Prop 65 lawsuits using ICP-MS heavy metal testing per AOAC 2015.01 (SOP 046) under our PJLA ISO/IEC 17025 scope. However, standard labs often rely on ICP-OES, which has detection limits in the ppm range — too high for Prop 65. In contrast, our ICP-MS reaches parts-per-billion (ppb) sensitivity, which is essential for accurate California Prop 65 testing and, importantly, for preventing False Pass results that lead to litigation.

Wider element panel: When buyers need more than the Big 4, we extend coverage to a 13-element ICP-MS panel (Zn, Cu, Se, Cr, Mn, Sn, Na, K, Ca, Mg, Fe, Al, Ni) per AOAC 985.01 / 993.14 (SOP 047).

Target Analytes (Big 4):
  • Lead (Pb): The #1 cause of Prop 65 notices.
  • Cadmium (Cd): Common in cocoa, seeds, and shellfish.
  • Arsenic (As): Total arsenic by ICP-MS — conservative screen for the inorganic NSRL. AGT does not offer arsenic speciation.
  • Mercury (Hg): Concern for seafood products.
Daily exposure calculation example for California Prop 65 compliance (Concentration x Serving Size = micrograms per day)
Risk Assessment

Exposure Calculation for Prop 65

Prop 65 limits are based on Total Daily Exposure (µg/day), not just concentration (ppm). In other words, a simple concentration number doesn't tell the full story. Therefore, we perform the critical math for you:

The Exposure Formula:
Concentration (ppm) × Daily serving size (g) = Exposure (µg/day)

Example: A protein powder has 0.1 ppm Lead.
• If serving is 5g: 0.1 × 5 = 0.5 µg/day (PASS)
• If serving is 50g: 0.1 × 50 = 5.0 µg/day (FAIL — Warning Required)

In addition, we help you define the correct serving size and compare your results directly against the MADL (Maximum Allowable Dose Level). Accurate California Prop 65 testing combines low-level ICP-MS data with this exposure math; otherwise, failure to meet Safe Harbor limits can result in costly litigation.

Technical Capabilities

Using advanced ICP-MS technology to reach parts-per-billion (ppb) detection under our ISO/IEC 17025 scope.

Analyte Method Reference Technique Typical Limit of Quantitation (LOQ)
Lead (Pb)AOAC 2015.01, SOP 046ICP-MS5 ppb (0.005 ppm)
Cadmium (Cd)AOAC 2015.01, SOP 046ICP-MS5 ppb (0.005 ppm)
Arsenic (Total)AOAC 2015.01, SOP 046ICP-MS10 ppb (0.010 ppm)
Mercury (Hg)AOAC 2015.01, SOP 046ICP-MS5 ppb (0.005 ppm)
13-Element Metals PanelAOAC 985.01 / 993.14, SOP 047ICP-MSvaries by analyte

Industries We Serve

California Prop 65 testing across the food & beverage categories most often cited in 60-Day Notices.

Chocolate and cocoa products tested for cadmium and lead under California Prop 65

Chocolate & Cocoa

Cadmium and lead screening for chocolate bars, cocoa powder, and confectionery — the highest-volume Prop 65 lawsuit category.

Protein and greens powders tested for heavy metals under Prop 65

Protein & Greens Powders

Heavy-metal verification for plant-based protein and greens powders, where concentrated plant matter aggregates soil metals.

Rice and cereal grain products screened for total arsenic under California Prop 65

Rice & Cereal Grains

Total arsenic screening for rice, rice-based foods, and infant cereals as a conservative proxy for the inorganic arsenic NSRL.

Seafood tested for mercury and cadmium under California Prop 65

Seafood & Sea Vegetables

Mercury and cadmium quantification for large fish, shellfish, kelp, and seaweed products with marine bioaccumulation risk.

Understanding Prop 65 Safe Harbor Limits

Prop 65 sets specific limits for Cancer (NSRL) and Reproductive Toxicity (MADL). Notably, exceeding these requires a warning label. Our guide to Prop 65 safe harbor levels for lead, cadmium and arsenic shows how to convert a lab result into per-serving exposure.

Lead (Pb) Limit

0.5 µg/day (MADL)
This is the most strictly enforced limit. As a result, consuming just one serving containing >0.5 micrograms of Lead may trigger a warning requirement.

Cadmium (Cd) Limit

4.1 µg/day (MADL)
This is often an issue in chocolate, sunflower seeds, and spinach. Consequently, exceeding this daily intake level poses a reproductive toxicity risk.

Arsenic Limit

10 µg/day (NSRL)
The Prop 65 NSRL applies specifically to Inorganic Arsenic (the toxic form). For this reason, our scope reports Total Arsenic by AOAC 2015.01, which is the conservative screening proxy. AGT does not offer arsenic speciation.

Common At-Risk Product Categories

Heavy-metal exposure varies sharply by ingredient. As a result, these categories most often trigger California Prop 65 testing reviews.

Product Category Primary Metal of Concern Typical Safe Harbor Risk
Chocolate & Cocoa ProductsCadmium, LeadHigh — bean origin and shell residue drive elevated levels
Protein & Greens PowdersLead, Cadmium, ArsenicHigh — concentrated plant matter aggregates soil metals
Rice & Rice-Based FoodsArsenic (reported as total arsenic)High — rice uptakes arsenic from paddy soils
Seaweed & Sea VegetablesInorganic Arsenic, CadmiumHigh — marine bioaccumulation
Seafood (large fish, shellfish)Mercury, CadmiumHigh — top of the food chain accumulation
Sunflower & Pumpkin Seeds, SpinachCadmiumModerate — naturally cadmium-accumulating crops
Spices, Herbs & BotanicalsLead, CadmiumModerate–High — soil contamination and processing exposure

Common Questions About California Prop 65 Testing

Expert answers for food manufacturers regarding Prop 65 compliance.

What is the legal limit for Lead under Prop 65?
The "Safe Harbor" limit (MADL) for Lead is 0.5 micrograms per day. Specifically, this is calculated by multiplying the concentration in your food (ppm) by the serving size (grams). Consequently, if the result is >0.5, a warning label is required unless you can prove the lead is "naturally occurring."
What is a "60-Day Notice"?
A 60-Day Notice is a legal document sent by a private enforcer (bounty hunter) alleging that your product contains chemicals above the safe harbor level without a warning. If you receive one, you then have 60 days to respond before a lawsuit is filed. Therefore, proactive California Prop 65 testing helps prevent this by ensuring your labels are accurate before sale.
Are Organic products exempt from Prop 65?
No. "Organic" refers to how food is grown (no synthetic pesticides), but heavy metals are naturally in the soil. As a result, organic status offers no protection against Prop 65.
How is Prop 65 different from FDA regulations?
FDA action levels and interim reference levels address total dietary exposure, whereas Prop 65 safe harbor levels (NSRLs for cancer, MADLs for reproductive harm) apply to the daily exposure from a single product. Prop 65 thresholds are usually stricter — for lead, the 0.5 µg/day MADL sits several times below FDA's interim reference levels — which is why dedicated California Prop 65 testing is needed even for FDA-compliant products. As a result, a product can be FDA compliant but still illegal to sell in California without a warning.
Does a positive test mean I cannot sell my product?
No. Prop 65 is a "Right to Know" law, not a ban. In other words, you can still sell your product if it exceeds the limit, but you MUST place a compliant Prop 65 Warning Label on the package. Ultimately, failure to warn is what leads to lawsuits.

Don't Wait for a Notice of Violation.

Schedule accredited California Prop 65 testing today and sell with confidence in the California market.

Request a Prop 65 Screen
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