Written statement according to Proposition 65
I am asked to give a written statement according P65 (Safe Drinking Water And Toxic Enforcement Act Of 1986) to our customer located in California. We are a biscuit manufacturer in Germany exporting products to the US. This question arises the first time. I understood that this proposition (about 900 substances) is not only for water but for all products. Nobody is able to analyse all the catogeries of substances, not from the analytical point of view, not from the costs.
I am sure that we will fulfill nearly all requirement because we are producing under European/German food law. But we don't have analytial data. A lot of these substances are monitored be companies and govermental organization, but not on batch level.
Especially for drinking water we have in Germany one of the highest standard worlwide.
But there is another point: As a biscuit manufacturer we know the acrylamide in generated during processing. Since 10 years we have a program installed in Germany (now in the EC too) to minimize the acrylamide development. In many cases we could acieve reduction rates of >> 90%. In my opinion this kind of food borne contaminant is not meant but the chemical from polyacrylamide production. Same for ethanol. What's with ethanol from yeast fermentaion in cakes (traces after baking)? There are some of such examples.
How US located manufacturer deal with this topic? Do they have special packs for California bearing a warning?
Please assist in finding a solution.
Rgds moskito
Rgds moskito
Dear all
I am asked to give a written statement according P65 (Safe Drinking Water And Toxic Enforcement Act Of 1986) to our customer located in California. We are a biscuit manufacturer in Germany exporting products to the US. This question arises the first time. I understood that this proposition (about 900 substances) is not only for water but for all products. Nobody is able to analyse all the catogeries of substances, not from the analytical point of view, not from the costs.
I am sure that we will fulfill nearly all requirement because we are producing under European/German food law. But we don't have analytial data. A lot of these substances are monitored be companies and govermental organization, but not on batch level.
Especially for drinking water we have in Germany one of the highest standard worlwide.
But there is another point: As a biscuit manufacturer we know the acrylamide in generated during processing. Since 10 years we have a program installed in Germany (now in the EC too) to minimize the acrylamide development. In many cases we could acieve reduction rates of >> 90%. In my opinion this kind of food borne contaminant is not meant but the chemical from polyacrylamide production. Same for ethanol. What's with ethanol from yeast fermentaion in cakes (traces after baking)? There are some of such examples.
How US located manufacturer deal with this topic? Do they have special packs for California bearing a warning?
Please assist in finding a solution.
Rgds moskito
Nobody with experience?
Rgds moskito
Dear moskito,
I'm not in California (or USA) but the basic answer to yr query appears to be detailed here (see "What requirements does Proposition 65 place on companies doing business in California?") -
http://www.prop65cle...in-english.html
Assuming yr customer is American (and in California), I think most suppliers would expect him/her to advise the appropriate response ?. (Or perhaps recommend a lawyer )
It certainly is an amazing document.
Rgds / Charles.C
Dear moskito,
I'm not in California (or USA) but the basic answer to yr query appears to be detailed here (see "What requirements does Proposition 65 place on companies doing business in California?") -
http://www.prop65cle...in-english.html
Assuming yr customer is American (and in California), I think most suppliers would expect him/her to advise the appropriate response ?. (Or perhaps recommend a lawyer )
It certainly is an amazing document.
Rgds / Charles.C
Just another reason why California has been/is slitting it's collective throat via regulation.
Obviously, you are not going to try to sell anything that will give people cancer, but most manufacturers simply choose to include the generic
"WARNING: This product contains a chemical known to the State of California to cause cancer." on their products.To me, this is just as much a cop out as the "may contain" label. I know I did not offer any substantive answer to the question. I'm just pointing out that sometimes legislation that is supposed to "protect" the consumer does no such thing. It just provides a loophole. Marshall
I'm no expert, but if you are providing a product that will be sold in California that contains any of the "bad" substances, you don't have to do much other than include the suggested warnings on your specifications or on your finished product label. Once you have done that, presumably, it's perfectly legal to be sold/purchased in California. It then becomes the consumers decision whether or not to buy the product.