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Vol. 1511 | 04 Jan 2026

Under OEHHA’s Vinyl Acetate guidance, only exposure to the free monomer - based on realistic use conditions - triggers Proposition 65 warnings, while Vinyl Acetate polymers and copolymers themselves are not directly subject to the warning requirement.

The Office of Environmental Health Hazard Assessment (OEHHA) has issued information letters regarding Vinyl Acetate, effective January 3, 2026. The Carcinogen Identification Committee (CIC) listed the chemical Vinyl Acetate (CAS #: 108-05-4) as a carcinogen in the Proposition 65 list on January 3, 2025.

The letter clarifies that even though Vinyl Acetate polymers are present in many products, the warning requirement only targets the free monomer and not the polymers (Polyvinyl Acetate, Polyvinyl Alcohol, Polyvinyl Acetals, Ethylene-vinyl acerate copolymers, Polyvinyl chloride-acetate copolymers and Vinyl acerate-vinyl laurate copolymers). The monomer is uncommon in consumer products, but residual unreacted monomer may be present in some products made with Vinyl Acetate polymers and copolymers.

The ideal test for this chemical would reflect the amount of Vinyl Acetate released from the product or present in the product during use or at other times when exposure is possible The test results should not be based on the amount of Vinyl Acetate obtained through the dissolution of Vinyl Acetate-containing polymers, if such dissolution is unlikely to occur during the foreseeable use, purchase, storage, maintenance or repair of the product.

Businesses must assess and determine if the products present a significant exposure to the monomer to decide if a Proposition 65 warning is needed.

For questions, please contact Andrew Loveland (andrew.loveland@intertek.com) and Harini Ramaswamy (harini.ramaswamy@intertek.com).

If you have any questions, please contact:

Image of Harini Ramaswamy
Harini Ramaswamy

Technical Manager, Softlines

Harini provides technical and regulatory support on consumer products testing to retailers in North America. She supports global labs, engages with regulatory bodies, industry groups and standards organizations. Harini holds a master’s degree in Design (Apparel Studies) from the University of Minnesota and B. Tech in Apparel Technology from Anna University, Chennai. Her functional apparel design projects presented at the Industrial Fabrics Association International (IFAI) and Techtextil conferences have won her numerous accolades. 

Email:  harini.ramaswamy@intertek.com

Image of Andrew Loveland
Andrew Loveland

Technical Director - Hardlines, Softlines and Toys

Andrew brings over 20 years of experience in the regulatory compliance and technical services industry relating to consumer products. With a background in electrical engineering, he advises on the technical aspects of identification and application of regulatory requirements and appropriate test methods necessary to measure safety, quality, and performance of consumer products. Andrew often advises retailers and suppliers on appropriate actions to effectively manage compliance risks.  

Email:  andrew.loveland@intertek.com  

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