Settlement Date:
07/29/2026
Case Name:
CAG v. Wooltari USA, Inc.
Court Name:
Alameda County Superior Court
Plaintiff:
Consumer Advocacy Group, Inc.
Injunctive Relief:
3.1 After the Effective Date, Defendant shall not manufacture for sale in California,
any Covered Products that exceed the levels of Lead, Arsenic, and Cadmium, (“reformulation
level(s)”) specified in sections 3.1.-3.1.3 below unless Proposition 65 compliant warnings are
provided as set forth in the following paragraphs.
3.1.1 Lead: an exposure of no more than 0.5 micrograms of Lead based on a single
serving of the Covered Product per day. For purposes of assessing compliance with this
reformulation level, the exposure shall be calculated by multiplying the recommended
product label serving size of the Covered Products by the concentration of Lead in the
Covered Products.
3.1.2 Cadmium: an exposure of no more than 4.1 micrograms of Cadmium based
on a single serving of the Covered Product per day. For purposes of assessing compliance
with this reformulation level, the exposure shall be calculated by multiplying the
recommended product label serving size of the Covered Products by the concentration of
Cadmium in the Covered Products.
3.1.3 Arsenic: a level of no more than 20 parts per billion (“ppb”) of Arsenic.
3.2 For any Covered Products that exceed the reformulation level of Listed Chemicals
set forth in sections 3.1.1-3.1.3 above that are manufactured for distribution and/or sale into
California after the Effective Date, Defendant must provide a Proposition 65 compliant warning for the Covered Products pursuant to Proposition 65 and its implementing regulations as set forth
below. The language of the warnings and method for providing any warnings for the Covered
Products shall be compliant with Title 27, California Code of Regulations, § 25600, et seq. and
with Title 27, California Code of Regulations, § 25607.1, et seq. for birth defects or other
reproductive toxicity. Defendant shall provide warnings for cancer if the exposure to Lead is
greater than 15 ug/day when averaged over a lifetime or if the exposure to Inorganic Arsenic
Compounds is greater than 10 ug/day when averaged over a lifetime. Any warning provided
pursuant to this section shall be affixed to the packaging of, or directly on, the Covered Products,
and be prominently placed with such conspicuousness as compared with other words, statements
designs, or devices as to render it reasonably likely to be read and understood by an ordinary individual under customary conditions before purchase or use. The warning must be set off from
other surrounding information and enclosed in a box. Where the packaging of the Covered
Products or a sign referring to the Covered Products includes consumer information as defined by
California Code of Regulations title 27 §25600.1(c) in a language other than English, the warning
must also be provided in that language in addition to English. Should Defendant sell or distribute
any Covered Products through the internet into California where Defendant controls the product
listing, the warning shall be posted in the manner as provided for internet sales in 27 CCR sections
25601 and 25602, as they may be subsequently amended, for sales to consumers in California. The
Parties agree that the following warning language shall constitute compliance with Proposition 65
with respect to the alleged Cadmium and/or Lead and/or Arsenic contained in the Covered
Products manufactured by or for Defendant as applicable after the Effective Date:
For Lead
[CALIFORNIA] or |CA] WARNING: Consuming this product can expose you
to chemicals including Lead, which is known to the State of California to cause
cancer and birth defects or other reproductive harm. For more information go to
www.P65Wamings.ca.gov/food
For Cadmium
[CALIFORNIA] or [CA] WARNING: Consuming this product can expose you to
chemicals including Cadmium, which is known to the State of California to cause birth
defects or other reproductive harm. For more information go to
www.P65Wamings.ca.gov/food
For Arsenic
[CALIFORNIA] or [CA] WARNING: Consuming this product can expose you to
chemicals including Arsenic, which is [are] known to the State of California to
cause cancer and birth defects or other reproductive harm. For more information
go to www.P65Wamings.ca.gov/food
3.3 The injunctive requirements of Section 3 shall not apply to Covered Products that
are manufactured or are otherwise already in the stream of commerce as of the Effective Date,
which Covered Products are expressly subject to the releases provided in Section 5.
3.4 Changes in the law and regulations applicable to Proposition 65, including changes
resulting from federal and/or state court rulings, occurring after this date may be incorporated into
the terms of this Consent Judgment, pursuant to the modification provisions set forth in Section 7.
*Non-Contingent Civil Penalty:
$ 57,160.00
Attorney(s) Fees and Costs:
$ 325,000.00
Payment in Lieu of Penalty:
$ 42,840.00 (Defendant or their agents shall make a
separate payment, in the amount of forty-two thousand eight hundred and forty dollars
($42,840.00) as an additional settlement payment to “Consumer Advocacy Group, Inc.” pursuant
to Health & Safety Code § 25249.7(b) and California Code of Regulations, Title 11 § 3203(d).
Defendant or their agents will issue a separate check to CAG for the Additional Settlement
Payment. CAG will use this payment as follows, seventy-five percent (75%) for fees of
investigation, purchasing and testing for Proposition 65 listed chemicals in various products, and
for expert fees for evaluating exposures through various mediums, including but not limited to
consumer product, occupational, and environmental exposures to Proposition 65 listed chemicals, and the cost of hiring, consulting, and retaining experts who assist with the extensive scientific
analysis necessary for those files in litigation and to offset the costs of future litigation enforcing
Proposition 65 but excluding attorney fees; twenty-five percent (25%) for administrative costs
incurred during investigation and litigation to reduce the public’s exposure to Proposition 65 listed
chemicals by notifying those persons and/or entities believed to be responsible for such exposures
and attempting to persuade those persons and/or entities to reformulate their products or the source
of exposure to completely eliminate or lower the level of Proposition 65 listed chemicals including
but not limited to costs of documentation and tracking of products investigated, storage of
products, website enhancement and maintenance, computer and software maintenance,
investigative equipment, CAG’s member’s time for work done on investigations, office supplies,
mailing supplies and postage. Within 30 days of a request from the Attorney General, CAG shall
provide to the Attorney General copies of documentation demonstrating how the above funds have
been spent. CAG shall be solely responsible for ensuring the proper expenditure of this Additional
Settlement Payment.)
Total Payments:
$ 425,000.00
Will settlement be submitted to court?
Contact Organization:
Yeroushalmi & Yeroushalmi
City, State, Zip:
Beverly Hills, CA 90212
Phone Number:
(310) 623-1926
