Proposition 65, FDA, and HumphreyLine

HumphreyLine shares the concerns currently being expressed by many promotional product distributors about contaminated products from overseas and the risk of legal liability under California’s Proposition 65 and other similar regulations.  This explains our position on this important matter.

HumphreyLine retained a prominent California law firm that is a leader in Prop 65 litigation, and hired them to provide us with a legal opinion on what levels of the various chemicals listed under Prop 65. There is no statute governing Prop 65; it was a voter initiative, and the standards have

been derived through thousands of settlement agreements in litigation. While there are no “safe harbor” standards available, there are measurable levels that have been developed through the court system and these are now generally accepted in California.

The legal opinion letter laid out the generally accepted levels of the chemicals that have been litigated.  We then took samples of our product line that included substantially every material, ink, and manufacturing process we use. We had these products evaluated by an independent testing laboratory for substance levels of these key chemicals.  The results show that all of our products are well below the threshold levels defined in the opinion letter.

There is the inherent risk that the standards may change, depending on future litigation settlements; but as of now, HumphreyLine’s full product line is in compliance with Prop 65.

In addition, the FDA has inspected our facility and determined that we are fully compliant with the relevant regulations governing our re-labeling activities for personal care amenities.  And regarding our plastic resins, all are certified to meet food contact safety standards established through the FDA.

If there are any questions you may have about these important issues, please contact us.