My skincare product label has a Prop 65 warning. Should I worry?

My skincare product label has a Prop 65 warning. Should I worry?

  • Jul 30, 2020
  • Kim Howard

While well-intentioned, California's Prop 65 — officially “The Safe Drinking Water and Toxic Enforcement Act of 1986” — has led to unintended consequences, especially when it comes to products made with the cannabis plant, including Green Bee Botanicals skincare.   

We appreciate this law; it's meant to inform California consumers about food, water, dietary supplements, and other consumable products that may have ingredients that can cause cancer or birth defects. 

Green Bee Botanicals products are actually exempt from Prop 65 and do not require this warning. However, because some cannabis dispensaries will not sell products without this warning — and our products currently can be bought only from dispensaries — we include it. 

The important thing to know is that: 

All of our products pass the strict California cannabis testing requirements, which are stricter than organic food testing.
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We publish these test results, called COAs (certificates of analysis), for all our products on each of our online product pages.
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Our products will not cause cancer. They are not dangerous. Read on to understand why. 

 

Green Bee Botanicals Renewing Face Serum certificate of analysis COA clean beauty

 

First off, Prop 65 is not a product safety law; it’s a right-to-know law, which means we’re required to inform the public that a chemical from the Prop 65 list is present in a product, even if in trace amounts. 

Second, the California Office of Environmental Health Hazard Assessment (OEHHA) states: 

“A Proposition 65 warning does not necessarily mean that a product is in violation of any product-safety standards or requirements.”

 

It's a painful irony to have to include Prop 65 cancer warnings on our cannabis skincare products when they are literally among only a handful of the cleanest and safest available today — with proof no less, in our posted COAs. Green Bee Botanicals was created by Bridget May specifically to make safe, clean products with safe, clean ingredients because there are so few available on the market today.  

So why do cannabis products sold in California have to have the Prop 65 warning on them?

In 2009, marijuana smoke was added to the Prop. 65 list of chemicals known to cause cancer, so all cannabis flower is subject to Prop. 65 warnings. Additionally, if even trace amounts of any chemical on the Prop 65 list of over 1,000 chemicals might be found in a product, even if it's naturally-occurring, not added or synthetic, the warning is required. 

In our case, this naturally-occurring chemical is a terpene called beta-myrcene (aka β-myrcene or myrcene). Natural terpenes give plants their distinctive scents, such as the citrusy smell of lemons and the crisp, refreshing scent of pine trees. Myrcene is found in fruits, vegetables, tree nuts, and plants, such as mangoes, hops, bay leaves, lemongrass, eucalyptus, verbena, citrus, pomegranates, carrots — and, you guessed it, cannabis plants. 

So why don't mangoes containing myrcene require Prop 65 warning stickers but our skincare products do? The short answer is that pomegranates and carrots are classified by the government as "foods," while cannabis is not. Section § 25501 of the California Code of Regulations, "Exposure to a Naturally Occurring Chemical in a Food," exempts fruits and food from the prop 65 warnings requirements. 

 

Photo by Food Photographer | Jennifer Pallian | Unsplash

Photo by Food Photographer | Jennifer Pallian | Unsplash

 

We're glad foods are exempt. Putting cancer warnings on carrots would be absurd. We think it is equally absurd to require it on natural cannabis products, especially those that aren't ingested or smoked, such as our skincare. 

The fact that myrcene is even on the list of Prop 65 chemicals at all is controversial. US and EU food regulatory agencies agree β-myrcene raises no safety concern. Scientists and others argue that the study cited for its inclusion in Prop 65 not only states that β-myrcene did not show genotoxicity or mutagenicity (the ability of chemicals to damage cells or cause mutations), but multiple independent studies have concluded that myrcene is "not mutagenic" as well, including this one and this one. New studies even suggest that myrcene has antioxidant, anti-inflammatory, and analgesic (pain-relieving) properties, including this one. 

Lastly, the report cited for adding myrcene to Prop 65 states, “Positive results demonstrate that a chemical is carcinogenic for laboratory animals under the conditions of the study and indicate that exposure to the chemical has the potential for hazard to humans.” The study conditions are key, as they used a minimum of 0.25 grams of myrcene per kilogram of body weight per rat. That is the equivalent of a 150-pound person consuming 17 grams of myrcene per day, an astronomically high amount. 

To give you an idea what that would mean in everyday conditions: using beer as an example (since myrcene is a naturally-occurring compound in hops): A 150-pound person would have to consume 9 gallons of hoppy beer per day, or 3,285 gallons of beer per year, to get that much myrcene. The average American adult drinks 26 gallons of beer per year. Do the math. It’s akin to saying someone who eats 10,000 carrots per day is at risk of getting cancer from it.   

Nonetheless, because we infuse our skincare with full-spectrum cannabis, which may contain trace amounts of naturally-occurring myrcene — which presents no actual risk to you — we must slap this warning on there. And because some dispensaries are extremely careful around legal compliance, they require a Prop 65 warning label on every product, even if a product is exempt from Prop 65 (as ours are).  

So, to comply with the strictest reading of the regulations, we include these warnings with each product:

"This product can expose you to chemicals including myrcene, which is known to the State of California to cause cancer and reproductive harm. For more information go to: www.P65Warnings.ca.gov." 

Take it with a grain of salt. We appreciate the efforts of our lawmakers’ to keep us safe. We also recognize that some of these efforts have the unintended consequence of labeling healthy, healing ingredients as potentially hazardous. Topically-applied creams and oils infused with organic plants and cannabis are not dangerous. Green Bee Botanicals products are safe, pure, clean, and good for you. We use them ourselves. We care about the health of our customers, and go to great lengths to keep you safe. You can always read the test results of each product to verify. 

There's plenty of other ingredients to be wary of with personal care products (read more about toxins lurking in mainstream cosmetics products here). 

If you have any questions about testing, safety, or want to talk about California cannabis regulations, or cosmetic safety, we are just a phone call, email, or DM away! 

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