On 3rd Feb 2026, Vietnam Metal Hardware Co., Ltd and Vietnam Metal Furniture Co., Ltd passed at the same time the PROP 65 (California – US) & LEAD (US: 116 CFR Part 1303 – Lead in Paint ≤ 90 ppm & EU: REACH / ECHA – Lead restrictions https://echa.europa.eu/hot-topics/leadon Surface Painting ICD Brass Black on Stainless Steel
1. California Proposition 65 (PROP 65) (Safe Drinking Water and Toxic Enforcement Act of 1986) requires businesses to provide warnings for products exposing consumers to chemicals known to cause cancer, birth defects, or reproductive harm. It forces disclosure of over 900 listed chemicals on labels, signs, or in workplaces.
Key details regarding Prop 65 include:
Application: Applies to any company with 10+ employees selling products in California or operating there.
Warning Requirement: A "clear and reasonable" warning must be provided if products contain listed chemicals above safe harbor levels.
Common Affected Products: Toys, jewelry, furniture, tableware, electronics, and clothing.
Enforcement: Conducted by the California Attorney General, district attorneys, or private individuals, often resulting in 60-day notices for violations.
2. 16 CFR Part 1303 is a U.S. federal regulation banning paint and similar surface coatings containing lead in excess of 0.009% (90 parts per million - ppm) by weight in consumer products, particularly children's products and household furniture
.This limit was established by the Consumer Product Safety Improvement Act (CPSIA) of 2008, effective August 14, 2009.
Scope: Applies to paint/coatings on toys, children's products, furniture, and residential surfaces.
Definition of Paint: Covers liquid, semi-solid, or solid films applied to surfaces such as wood, metal, paper, or plastic.
Limit: The total lead content must not exceed 90 ppm (0.009%) of the total nonvolatile content or the weight of the dried paint film.
Exemptions: Generally does not apply to certain industrial, automotive, or marine paints, or printing inks that become part of the substrate.
Penalty: Products exceeding this limit are considered banned hazardous products under the Consumer Product Safety Act.
For children's products, this 90 ppm limit applies specifically to the paint/coating, while a separate 100 ppm total lead limit applies to the accessibility of the substrate components.
3. Under REACH Regulation , the European Chemicals Agency (ECHA)has implemented strict limitations on lead to protect human health and the environment, focusing on reducing exposure to this toxic substance. Key restrictions include a 0.05% limit in consumer products, bans on lead in paints, PVC (0.1%), and jewelry, along with restrictions on lead gunshot in wetlands.
Key ECHA Lead Restrictions & Initiatives
Consumer Products (General): As of June 1, 2016, lead in articles supplied to the general public that can be mouthed by children is restricted to 0.05% by weight. This applies to clothing, footwear, accessories, and toys.
PVC Products: As of November 29, 2024, lead and its compounds are banned in new PVC articles at concentrations of 0.1% or higher.
Jewelry: Lead is restricted in jewelry to prevent exposure, particularly for children.
Paints: Lead carbonates and sulphates are prohibited in paints.
Shooting and Fishing:
Wetlands: A ban on discharging lead shot in or around wetlands is in effect as of February 2023.
Outdoor Shooting/Fishing: ECHA is actively proposing to expand restrictions on lead ammunition and fishing sinkers.
Drinking Water: The Drinking Water Directive restricts lead, with a maximum allowable limit of 10 𝜇g/l, tightening to 5 𝜇g/l by January 2036.
Regulatory Status
Lead is recognized as a Substance of Very High Concern (SVHC). ECHA continues to monitor its use and has proposed broader restrictions for its usage in various industries, including ammunition, to reduce environmental and health risks.
𝜇g/l, tightening to 5 
