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About Prop 65 | Gains in Bulk

CALIFORNIA
Proposition 65

Why some of our products carry a California Prop 65 warning.

WHAT PROP 65
ACTUALLY IS.

California passed Proposition 65 in 1986 — officially the Safe Drinking Water and Toxic Enforcement Act. It is a right-to-know law. The state maintains a list of around 900 chemicals it considers a potential cancer or reproductive risk.

Any business that sells products into California has to post a notice when its product contains a measurable amount of any chemical on that list. That is the entire mechanism.

The state doesn't approve products. It doesn't ban products. It doesn't recall products. It requires disclosure. Then it lets the consumer decide.

The chemical list is broad. It covers things you'd expect — industrial solvents, plastics, certain pesticides — and a lot of things you wouldn't. Trace lead in cocoa. Trace cadmium in leafy greens and organ meats. Trace arsenic in rice.

All of these occur naturally in the soil, water, and food chain. All of these are on the list.

California sets the threshold for posting a notice extraordinarily low. In many cases, lower than what the FDA or EPA flag as a health concern. The whole point is over-disclosure, not under-disclosure.

WHAT IT'S NOT.

Prop 65 is not a federal safety verdict. The FDA doesn't issue Prop 65 warnings. The EPA doesn't issue Prop 65 warnings. The state of California does, on its own authority, using its own thresholds.

It is also not a recall. Not a finding of any kind. Not a determination that any specific product is unsafe.

It is, more boringly than the word "warning" suggests, a disclosure obligation. The state isn't telling you "stop." It's telling you "know."

If this distinction feels like the kind of thing that matters more to lawyers than humans, here's the cleaner version. The State of California itself, on its own Prop 65 fact sheet for foods, comes right out and says it.

In California's Own Words

"This does not mean that these foods and beverages should never be consumed."

— Office of Environmental Health Hazard Assessment, State of California

ORGANIC vs.
INORGANIC.

Here's the part most people don't know about Prop 65, and it's the part that actually matters.

The chemicals on California's list are dangerous in their inorganic form — synthetic, industrial, chemically processed. Lead in old paint. Cadmium in batteries. Arsenic in industrial pesticides. That's the version of these chemicals the law was really written to protect people from.

But many of those same chemicals also exist naturally in soil, water, and the food chain. As a plant grows, it absorbs them. As an animal eats those plants, it stores them.

This is the organic form — bound to the natural food matrix, processed differently by your body, and present in everything you've ever eaten.

Prop 65 doesn't distinguish between the two. The disclosure threshold is the same whether the lead came from an industrial battery or a square of dark chocolate.

Some of the healthiest foods in the world — organic greens, dark chocolate, brown rice, organ meats, Brazil nuts — are above Prop 65 limits. If those foods were genuinely dangerous at those levels, anyone eating a clean organic diet would be at higher health risk than someone eating processed food. That isn't how it works.

BY THE NUMBERS.

"California sets the threshold extremely low" is easy to say. It's harder to picture without concrete numbers. Below are five different daily lead limits, drawn from different regulatory bodies, ordered from most lenient to most strict.

20 MCG
NSF International
Supplement industry standard, per day.
15 MCG
CA Prop 65
Cancer threshold, per day.
10 MCG
WHO
World Health Organization daily concern level.
3 MCG
US FDA
Pharmaceutical limit, per day.
0.5 MCG
CA Prop 65
Reproductive toxin trigger — the threshold that fires most disclosures.

California's reproductive toxin trigger of 0.5 mcg per day is 6× stricter than the FDA's pharmaceutical limit, 20× stricter than the World Health Organization's daily concern level, and 40× stricter than the supplement industry's NSF standard. By every other regulatory standard on the planet, the levels involved in our products are well within safe ranges. The notice exists because California chose to draw the line at the absolute strictest possible position — not because the products are unsafe by any other measure.

WHY SOME OF OUR PRODUCTS
ARE LISTED.

We make natural supplements. No synthetic fillers. No artificial sweeteners. No shortcuts. Every batch is third-party tested for heavy metals, microbials, and label accuracy. Our formulas meet or beat FDA safety guidance.

The trade-off of using real, whole-food ingredients is that real ingredients carry their natural mineral profile. Cocoa beans absorb trace lead from soil. Organ meats carry trace cadmium from the animal's diet. Both occur naturally. Both are present in the same foods you'd buy at any grocery store. Both are on California's Prop 65 list.

We could swap real cocoa for artificial chocolate flavoring. We could replace desiccated organ meat with a synthetic vitamin blend. The Prop 65 notice would go away. The product would also stop being what we built it to be.

So we keep the ingredients. We post the notice. We trust you with the information.

The notice is the cost of using real ingredients. The alternative is making a worse product to dodge a label. We're not willing to make that trade.

THE THREE PRODUCTS.

Lean Protein
Brownie

Trace lead in cocoa

This flavor uses real cocoa powder. Cocoa plants pull trace lead out of the soil they grow in — a well-documented fact across virtually every chocolate product on the market.

The actual amount in a serving is well within ranges considered safe by federal food authorities. California's threshold is significantly stricter, so we post a notice. If you'd rather skip it, our non-chocolate flavors don't carry one.

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Lean Protein
Cut Cake

Trace lead in cocoa

Same situation as Brownie. Cut Cake uses real cocoa as part of its flavor base. Same naturally occurring trace lead. Same Prop 65 notice. Same safety profile.

Real chocolate flavor comes from real cocoa. Real cocoa carries its natural mineral profile. We chose real over fake and accepted the disclosure that comes with it.

View Product →

Liver +
Kidney

Trace cadmium in organ meat

Desiccated grass-fed bovine liver and kidney. Organ meats are nature's multivitamin — densely packed with B12, retinol, choline, heme iron, and other bioavailable nutrients you can't easily replicate with synthetics.

They also naturally accumulate small amounts of cadmium, which is why California's own fact sheet recommends consuming organ meats in moderate amounts. That advice is built into how this product is dosed.

View Product →

THE CHOICE
WE MADE.

You can build a supplement company two ways. You can use synthetic chemistry, scrub every label clean, and never trigger any disclosure.

Or you can use real, whole-food ingredients and accept that real ingredients show up with their natural mineral profile attached.

We chose real. That choice gets us better products, real flavor, real bioavailability — and an obligation to be honest about what comes with it.

If California's threshold is the line, we'd rather post the notice than play games to get under it. The notice is the cost of doing this the right way. We're at peace with paying it.

If a brand isn't willing to disclose what's actually in their product, that should worry you a lot more than a brand that does.

If, after reading all of this, one of these products isn't for you, that's a fair call and we respect it.

DON'T TAKE OUR
WORD FOR IT.

California's own site is well-written and answers most questions in plain English. If you want the unfiltered version, here it is.

EXPLORE OUR PRODUCTS

† These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease. The Prop 65 information on this page is provided as a plain-English summary for our customers and is not a substitute for the official guidance published at p65warnings.ca.gov. If you have specific medical questions about your own health and supplement use, talk to your doctor.