Vinyl acetate, a chemical found in many products sold in the branded merchandise industry, was added to California’s Proposition 65 list as a carcinogen earlier this month. Experts recommend affected companies begin working with testing labs to either ensure the chemical is removed from products or to begin including a Prop 65 warning label on products that contain the chemical.

“Vinyl acetate is a versatile chemical used in various industries, particularly for its adhesive and polymerizing properties,” says Richard Yue, business leader of analytical testing services at AnnRay Testing, which operates product testing laboratories around the world. AnnRay Testing is the sister company of business services provider Insight Quality Services.

“It’s a building block for many products we encounter daily,” Yue says.

  • Vinyl acetate is a colorless, flammable chemical often found in products like paint, glue and adhesives, paper coatings, textile and leather finishings, plastics and inks.
  • It’s also used as a food additive and in chewing gums, microwave-heat-susceptor packaging, nail products and cigarette smoke.


The warning requirement for significant exposures to vinyl acetate will take effect on January 3, 2026.

A committee for the Office of Environmental Health Hazard Assessment (OEHHA) ruled by a unanimous vote in December that vinyl acetate was “clearly shown” through scientific research and testing to cause cancer, which led to the chemical’s addition to Prop 65.

  • Also known as the Safe Drinking Water and Toxic Enforcement Act of 1986, Prop 65 is a California law that requires businesses to warn state citizens about chemicals that can cause cancer, birth defects or other reproductive harm.

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Products containing chemicals found on Prop 65’s carcinogen list that are sold or manufactured in California must have a warning label if the chemicals exceed a certain “No Significant Risk Level.”

  • The OEHHA has yet to set a “No Significant Risk Level” for vinyl acetate.


Promo Perspective

Figuring out what products contain vinyl acetate may be challenging for some promo firms, according to Rick Brenner, MAS+, president of Product Safety Advisors and co-chair of PPAI’s 2024 Product Responsibility Summit.

“Chemical additions to the Prop 65 list are particularly challenging for the promotional industry because, for the most part, we buy or customize finished products that are designed by others,” says Brenner. “Sometimes, even getting a basic bill of materials for the primary components of a product can be difficult to obtain from the factory, let alone a chemical analysis. In most cases, the factories themselves will not know the chemical content of the materials they are using.”

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Brenner recommends promo firms start reaching out to testing labs to figure out whether their products contain the chemical.

“Even though enforcement will not begin until 2026, suppliers and importers should begin working with a testing lab like QIMA as soon as possible to determine whether any of their products, inks or other coatings contain vinyl acetate,” Brenner says. “That will give them time to determine a strategy – either a Prop 65 warning label or reformulating.”

Chemical additions to the Prop 65 list are particularly challenging for the promotional industry because, for the most part, we buy or customize finished products that are designed by others.”

Rick Brenner, MAS+

President, Product Safety Advisors

Business services provider QIMA says its lab in Hong Kong will be able to test for the chemical up to a certain limit.

“[Vinyl acetate] is the monomer in the production of polymers or copolymers like polyvinyl acetate, polyvinyl acetals and ethylene-vinyl acetate (EVA),” says Karolyn Helda, global services and technical services director at QIMA. “There may be a concern regarding the presence of vinyl acetate monomer residue in these polymers. Our QIMA lab in Hong Kong can test for vinyl acetate with reporting limit 0.1 mg/kg (ppm).”

However, the OEHHA hasn’t yet defined the testing method for vinyl acetate, stresses Noell Romatowski, retail business development manager at business services provider TUV Rheinland of North America.

“If members have a need to test the total content of vinyl acetate, we don’t have the test capability,” Romatowski says. “But if they’re looking for a specific migration of vinyl acetate to test, our labs in both Shenzhen and Taicang are capable.”

For questions or suggestions on regulatory or government affairs issues, please contact Rachel Zoch at RachelZ@ppai.org.