Is Your Cosmetic Bag Compliant? Navigating Prop 65 and REACH for PVC Products

You are launching a PVC cosmetic bag. But you are worried about complex chemical regulations like Prop 65 and REACH, and the huge risks of getting it wrong.

To ensure your PVC cosmetic bag is compliant, you must use certified materials, specifically request testing for phthalates and heavy metals, and work with a manufacturer who can provide official test reports from a third-party lab.

My mission is "Green Mission, Global Win-Win," which means I am committed to both sustainability and your success. Sometimes, a project requires a material like PVC for cost or functional reasons. In these cases, our "win-win" promise means we must help you navigate the safety and compliance landscape. It is not just about avoiding fines; it is about protecting your brand's reputation. For a designer like you, Jennie, I know that building trust with your clients is everything. That trust starts with a safe, compliant product. This is a co-creation process where we work together to meet every standard.
 

What does every brand need to know about Prop 65 & REACH regulations?

You see "Prop 65" and "REACH" in emails, but the legal jargon is confusing. You are not sure what these rules are, who they apply to, or what you need to do.

Prop 65 is a California law requiring a warning label if certain chemicals are present. REACH is a European Union law that restricts or bans the chemicals themselves. Both exist to protect consumers.

I help clients with this every day, so let me make it simple. Think of it like this: Prop 65 is like a warning sign, while REACH is like a roadblock. For a project with a brand who sold products across the US and Europe, we had to address both. For their California sales, we confirmed the specific bag did not require a Prop 65 warning label. For their European shipment, we provided a REACH test report proving the bag did not contain any banned substances. Understanding the difference was key to their successful global launch. A good manufacturing partner should be an expert in both so you do not have to be.

What is California Proposition 65?

Prop 65 is a "right-to-know" law that applies to products sold in California. It maintains a list of over 900 chemicals known to cause cancer or birth defects. If your product contains one of these chemicals above a very low "safe harbor" level, you are required to put a warning label on it. The warning usually says something like: "WARNING: This product can expose you to chemicals including [chemical name], which is known to the State of California to cause..." Failing to provide this warning can lead to large fines. It is not a ban, but a warning requirement.

What is EU REACH?

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. This regulation applies to all 27 countries in the European Union. Unlike Prop 65, REACH is focused on substance control. It identifies Substances of Very High Concern (SVHCs) and restricts them. If your product contains an SVHC above the legal limit (usually 0.1% by weight), you cannot sell it in the EU. There is no warning label option. To be REACH compliant means your product is proven to be free of these restricted chemicals.

What are the common chemicals of concern in PVC and how do you ensure compliance?

You know PVC can have "bad stuff" in it. But you do not know the specific chemicals to watch out for, which makes it hard to talk to your supplier about them.

The main chemicals of concern in PVC are phthalates, which make it soft, and heavy metals like lead and cadmium, found in cheap pigments. To comply, you must specify and verify "phthalate-free" and "low-heavy-metal" PVC.

Let me give you a real-world example. I was working with a new client who wanted a bright yellow PVC makeup bag. The first sample they got from another factory was incredibly cheap, but they felt unsure. They sent it to us for review. My team suspected the color might contain cadmium, a heavy metal used to make bright yellow and red pigments. We sent it for testing, and we were right. It was far above the REACH limit. We then co-created a new bag for them using our pre-tested, compliant PVC materials and a certified, cadmium-free yellow pigment. The price was slightly higher, but they gained total peace of mind. This is what it means to be a true partner.

Phthalates: The Plastic Softeners

These are a family of chemicals (like DEHP, DBP, BBP) added to PVC to make it soft and flexible. Without them, PVC would be rigid like a pipe. Many of these phthalates are on both the Prop 65 and REACH SVHC lists. The solution is simple for a knowledgeable manufacturer. We source PVC that uses modern, non-phthalate plasticizers. When you create your design, you just need to write on your technical sheet: "Material must be Phthalate-Free PVC." This clear instruction is the first step to ensuring compliance.

Heavy Metals: Lead and Cadmium

Lead and cadmium are other major concerns. They are not part of the PVC plastic itself, but they can be found in cheap color pigments or used as stabilizers to prevent the plastic from breaking down during manufacturing. They are highly toxic and heavily restricted. The only way to be sure your product is safe is to work with a manufacturer who has a reliable supply chain. We only buy raw materials from large, reputable sources who provide test reports for every batch. This commitment to quality at the source prevents problems from ever reaching your final product.
 

What is the compliance process, from material testing to final certification?

You know compliance is important. But the process of testing and getting a certificate seems like a complex, expensive black box you have no control over.

The process is simple: 1) Your manufacturer verifies the raw material with their supplier's reports. 2) For total assurance, they send a finished product to a third-party lab like SGS. 3) The lab issues your official pass/fail report.

I want to pull back the curtain on this process. It is a core part of how we provide a "win-win" for our clients. We see testing not as a burden, but as a final quality check that gives everyone peace of mind. The cost is actually very reasonable, usually just a few hundred dollars. I always tell my clients to think of it as insurance. You are spending a tiny fraction of your order's value to protect the entire investment. When you receive that official "Pass" report from a globally recognized lab, you have a legal document that proves your due diligence and protects your brand. It transforms anxiety into confidence.

Step 1: Raw Material Verification

The compliance journey starts before your bags are even made. As your manufacturing partner, we work with our PVC material suppliers to get test reports for the exact rolls of plastic that will be used for your project. We review these reports to ensure they meet REACH and Prop 65 standards from the beginning. For many clients, seeing these raw material reports is sufficient evidence of compliance and keeps costs down.

Step 2: Third-Party Lab Testing

This is the gold standard for compliance. We take a few finished products from your actual production run and send them to an independent, accredited laboratory. The biggest names in this field are SGS, Intertek, TUV, and Bureau Veritas. They are globally trusted, and their reports are accepted by every major retailer and government agency. The lab will test the bag for the specific lists of chemicals relevant to Prop 65 and REACH.

Step 3: Your Final Certificate

After a few days, the lab issues a detailed test report. This report is your certificate of compliance. It will list every chemical they tested for, the legal limit for that chemical, the amount detected in your product (which should be "ND" or "Not Detected"), and a final, clear verdict: "PASS." This document is your proof that you have done everything right. We send you the official PDF, and you should keep it in your files forever.
 

How do you work with your manufacturer to build a compliant supply chain?

You can't be in the factory yourself. You need to trust that your supplier is using the right materials and not cutting corners, but how can you be sure?

Build a partnership with a manufacturer who is proactive and transparent about compliance. They should provide documents willingly, explain their process clearly, and view safety as a shared goal, not your problem.

This is the most important part of my "co-creation" philosophy. A factory that hides information or gets defensive when you ask about compliance is a major red flag. A true partner welcomes your questions. They should have a standard process for compliance that they can explain to you. I recently started working with a designer, much like you, Jennie, who was developing a line for a major department store. Her first question to me was, "Can you walk me through your Prop 65 compliance protocol?" I was so happy she asked. We spent an hour on a video call where I showed her our raw material reports, sample third-party tests, and how we label everything for traceability. She said that call gave her the confidence to choose us as her partner.

Make Compliance Part of the First Conversation

Do not wait until you are about to place an order. Bring up compliance in your very first email. Ask potential suppliers: "What is your experience with Prop 65 and REACH for PVC products?" A good partner will have a clear, confident answer. They will tell you about their material sources and testing procedures. A factory that gives a vague or confusing answer is likely not experienced and is a risk you should not take.

A Partnership of Transparency

A compliant supply chain is a transparent one. Your manufacturer should make it easy for you to get the documents you need. At Rivta, we maintain a complete file for every single order. This file includes the original purchase order, the approved pre-production sample photo, the raw material certificates, and the final third-party test report. We can send you this complete "compliance package" at any time. This gives you the documentation you need for your retail partners and your own internal records, demonstrating a commitment to safety and social responsibility.

The Cost of Non-Compliance is Too High

I once heard a horror story from a brand owner who did not do their testing. Their shipment was stopped by customs, and a random test found high levels of lead. They lost the entire order, paid huge fines, and damaged their relationship with their retailer. The total loss was over six figures. The third-party test that would have prevented this entire disaster costs about $300. This is why our "win-win" approach includes compliance. By investing a small amount in testing, we protect you from catastrophic risk. It is the cheapest insurance policy you will ever buy for your brand.
 

Conclusion

Navigating Prop 65 and REACH is critical. By choosing a transparent partner and building a process of testing and verification, you protect your brand, serve your customers, and ensure a safe product.