Understanding Proposition 65: Complete Transparency from Frozen Garden

What You Need to Know

If you're seeing Proposition 65 warnings on our products, you might be confused, concerned, or wondering if you should avoid these products altogether. We want to provide you with complete transparency about what these warnings mean—and perhaps more importantly, what they don't mean.

What is California's Proposition 65?

Proposition 65, officially known as the Safe Drinking Water and Toxic Enforcement Act of 1986, is a California law that requires businesses to provide warnings about exposures to chemicals that California has determined cause cancer, birth defects, or other reproductive harm.

The law currently lists over 900 chemicals—and that list continues to grow. Here's the catch: many of these chemicals occur naturally in foods we've been eating safely for thousands of years.

Important: Frozen Garden does not intentionally add any Proposition 65 listed chemicals to our products. The elements that prompt labeling requirements are naturally occurring substances found in the fruits, vegetables, nuts, seeds, and spices we use—the same ingredients you'd find at any farmer's market or grocery store.

Let's Talk About the Reality of This Law

Here's What Makes Proposition 65... Unique (and Frustrating)

Proposition 65 doesn't consider context. The law treats a trace amount of a naturally occurring element in an organic spinach smoothie the same way it treats an industrial chemical in a toxic product. There's no distinction between:

  • Naturally occurring elements that plants absorb from soil (which has contained these elements since the beginning of time)
  • Synthetic chemicals deliberately added to products
  • Harmful industrial exposures versus trace dietary exposures from whole foods

The thresholds are incredibly low. For some chemicals, the "safe harbor" level requiring a warning is so low that it's virtually impossible to avoid triggering it with whole, natural foods. For example:

  • The daily threshold for lead is 0.5 micrograms—an amount found naturally in a single serving of many common vegetables like spinach, sweet potatoes, or carrots
  • The threshold for cadmium is 4.1 micrograms—a level that can be reached by eating certain nuts, seeds, or a square of dark chocolate

Only California requires these warnings. No other state, no federal agency (including the FDA), and no international food safety organization has determined that the trace levels of naturally occurring elements in whole foods pose a health risk requiring consumer warnings.

The law applies equally to wholesome foods and harmful products. A bag of organic spinach and a container of industrial paint thinner can both require the same warning label if they contain listed chemicals above the threshold—even though one is a nutritious vegetable and the other is a toxic chemical.

The Chemicals in Question

Lead and Cadmium

Where they come from: Lead and cadmium are naturally occurring elements that have existed in the earth's soil and water since the planet was formed. Plants absorb these elements through their roots as they grow—just as they absorb beneficial minerals like iron, calcium, and magnesium.

The reality: Nearly all foods contain some level of cadmium and lead. This includes:

  • Leafy greens (spinach, kale, lettuce)
  • Root vegetables (carrots, sweet potatoes, beets)
  • Fruits (apples, oranges, avocados, pineapples)
  • Nuts and seeds (almonds, cashews, walnuts, pumpkin seeds)
  • Grains (rice, oats, wheat)
  • Chocolate and cacao
  • Even drinking water contains trace amounts

In our products: Some Frozen Garden smoothies, overnight oats, garden bowls, and delites contain ingredients like spinach, nuts, seeds, or cacao powder that naturally contain these elements. The levels are consistent with what you'd find in these same ingredients purchased anywhere else—they're just part of eating plants.

FDA position: All Frozen Garden products fall within FDA guidelines for these elements. The FDA recognizes that trace amounts of heavy metals in food are unavoidable and has not established that the levels typically found in whole foods pose a health risk.

Acrylamide

Where it comes from: Acrylamide is a chemical compound that forms naturally when certain plant-based foods are cooked at high temperatures (above 248°F/120°C), particularly through frying, roasting, grilling, or baking. It's a byproduct of a chemical reaction between naturally occurring sugars and an amino acid called asparagine.

The reality: Acrylamide has been in the human diet since humans started cooking food with fire thousands of years ago. Common foods containing acrylamide include:

  • Coffee (one of the highest sources)
  • French fries and potato chips
  • Toasted bread and breakfast cereals
  • Roasted nuts and seeds
  • Baked goods (cookies, crackers, pastries)
  • Roasted vegetables
  • Prune juice
  • Canned black olives

In our products: Some Frozen Garden products contain roasted nuts (like peanuts). These ingredients undergo roasting to develop flavor and texture, which can create acrylamide—the same way your morning coffee or toast does.

Aflatoxins

Where they come from: Aflatoxins are naturally occurring compounds produced by certain molds that can grow on crops like peanuts, tree nuts, corn, and grains—particularly in warm, humid conditions.

The reality: The FDA closely monitors and regulates aflatoxin levels in foods. All peanuts and nuts sold in the United States must meet strict FDA safety standards.

In our products: A small number of our products contain peanuts. All of our suppliers meet FDA safety standards for aflatoxin levels.

What We're Doing About It

While we believe these warnings are often unnecessary and don't reflect actual health risks from whole foods, we take food safety seriously. Here's what we're doing:

  1. Reformulating where sensible: We're switching from roasted to raw pumpkin seeds in multiple products, and from fire-roasted to raw vegetables in our garden bowls. This reduces acrylamide without compromising nutrition.
  2. Sourcing quality ingredients: We work with suppliers who test for contaminants and follow strict quality standards.
  3. Being transparent: Rather than hide behind vague warnings, we're telling you exactly which ingredients trigger the warnings and why.
  4. Following all FDA guidelines: Every Frozen Garden product meets or exceeds FDA safety standards for all substances.

The Bottom Line

Should you be concerned about Proposition 65 warnings on our products?

Here's what the science says: The trace amounts of naturally occurring elements in whole, plant-based foods have been part of the human diet forever. Organizations like the FDA, USDA, and international food safety bodies have not determined that these levels pose a health risk.

The nutrients and health benefits of eating fruits, vegetables, nuts, seeds, and whole grains far outweigh any theoretical risks from trace amounts of naturally occurring elements. In fact, avoiding nutrient-dense foods like spinach, nuts, or dark chocolate because of Proposition 65 warnings could do more harm to your health than good.

Proposition 65 was created with good intentions—to warn consumers about harmful chemical exposures. But when applied to whole foods containing naturally occurring elements that have always been part of these foods, the warnings can be more confusing than helpful.

We include these warnings because California law requires us to, not because we believe our products pose any health risk when consumed as part of a balanced diet.

Questions?

If you have specific questions about any of our products or ingredients, please don't hesitate to contact us. We believe in complete transparency and are happy to discuss any concerns you may have.

For more information about Proposition 65, visit: www.P65Warnings.ca.gov

For the complete list of Proposition 65 listed chemicals, visit: OEHHA Proposition 65 Chemical List