Key takeaways
- Nickel release, not nickel content, is limited: below 0.2 µg/cm²/week for piercing posts, and no more than 0.5 µg/cm²/week for parts in direct and prolonged skin contact.
- Plated items must keep nickel release within 0.5 µg/cm²/week for at least two years of normal use. EN 12472 simulates that wear before the EN 1811 test.
- Each individual part of a jewellery article must contain less than 0.05% lead by weight, with limited exceptions such as crystal glass and vitreous enamels.
- Metal parts of jewellery, hair accessories and jewellery-making components must contain less than 0.01% cadmium by weight of the metal.
- An inspection checks materials, plating, findings and labels against the tested sample; release and content tests need an accredited lab.
Who it applies to and from when
The nickel limits began in Directive 94/27/EC, which amended Directive 76/769/EEC on dangerous substances. From 1 June 2009, REACH (Regulation (EC) No 1907/2006) replaced Directive 76/769/EEC, and the nickel rules became entry 27 of REACH Annex XVII. The restrictions apply to anyone placing the goods on the EU market, including importers. They apply to fashion and fine jewellery, watches, hair accessories and metal parts on garments.
Lead and cadmium in jewellery were added later: cadmium in entry 23 from 10 January 2012 (Regulation (EU) No 494/2011) and lead in entry 63 from 9 October 2013 (Regulation (EU) No 836/2012). See our overview of EU REACH for other restrictions that apply to the same goods.
Limits and test methods
| Item | Limit | REACH entry |
|---|---|---|
| Post assemblies inserted into pierced ears or other pierced parts of the body | Nickel release less than 0.2 µg/cm²/week | 27, para 1(a) |
| Earrings, necklaces, bracelets, chains, anklets, rings, watch cases, straps and tighteners, and rivet buttons, rivets, zips and metal marks on garments, in direct and prolonged skin contact | Nickel release no more than 0.5 µg/cm²/week from parts in skin contact | 27, para 1(b) |
| Those same articles with a non-nickel coating | Coating must keep release within 0.5 µg/cm²/week for at least two years of normal use | 27, para 1(c) |
| Any individual part of jewellery articles (including imitation jewellery, hair accessories, piercing jewellery, watches, brooches, cufflinks) and parts sold for jewellery-making | Lead below 0.05% by weight | 63 |
| Metal parts of jewellery, imitation jewellery and hair accessories, and metal beads and components for jewellery-making | Cadmium below 0.01% by weight of the metal | 23, para 10 |
The lead limit does not apply to crystal glass, internal watch parts that consumers cannot reach, natural or reconstructed precious and semi-precious stones not treated with lead, and enamels fused at 500 °C or more.
Test methods. Entry 27 requires the CEN standards to be used. The European Commission's December 2023 list names:
- EN 1811:2023, the reference test method for nickel release from piercing posts and articles in prolonged skin contact. It replaced EN 1811:2011+A1:2015.
- EN 12472:2020, which simulates accelerated wear and corrosion on coated items before the EN 1811 release test, to check the two-year coating rule.
- EN 16128:2015, for spectacle frames and sunglasses.
Lead and cadmium are limits on content by weight, so labs measure the total amount in each part after digesting it.
What this means for jewellery made in India
Jaipur makes fashion, silver and gemstone jewellery, and Moradabad is known for brass and other metal handicrafts, including fashion accessories. Garment trims such as buttons and rivets are covered too. The usual risks are:
- Nickel in base metals and plating. Nickel silver (German silver), some brass and white-metal alloys, and nickel underplating below gold or rhodium can release nickel once the top layer wears.
- Lead in castings and solder. Low-melting white metal and some soldered joints can contain lead above 0.05% by weight.
- Cadmium in alloys and solder. Cheap castings and brazing alloys are the main concern for the 0.01% limit.
- Mixed findings. Ear wires, posts, clasps and jump rings often come from different suppliers. Each part counts on its own, so a compliant pendant on a non-compliant chain still fails.
- Batch changes. A new casting alloy or plating line can change results. Ask for tests on production, not only on the first sample.
What inspection can check, and what needs a lab
| An inspector at the factory can check | Needs lab testing |
|---|---|
| Base metal, plating color and finish match the tested sample | Nickel release to EN 1811, with EN 12472 wear simulation for coated items |
| Ear posts, wires, clasps and findings come from the approved supplier and lot | Lead content of each part (entry 63) |
| Plating defects that expose the base metal: peeling, blistering, worn edges, pits | Cadmium content of metal parts (entry 23) |
| Labels, hangtags and packaging claims such as “nickel free” match the test evidence | Plating thickness checks, if the buyer specifies them |
| Simple nickel spot tests on surfaces, if the buyer asks, as a screening step only |
A spot test can flag obvious nickel on a surface, but it does not measure release in µg/cm²/week and cannot show compliance. Only EN 1811 results can do that.
How Clear To Load checks this in India
Our inspectors are based in Jaipur, Moradabad and Delhi NCR, among other cities. On a pre-shipment inspection or a handicrafts inspection, they compare metals, plating and findings with the tested sample, check plating defects and labels, and record results against your AQL. For EN 1811 and lead or cadmium tests, we draw random samples, seal them and send them to an ISO/IEC 17025-accredited lab you choose or we suggest, through lab testing coordination.
Reports arrive within 24 hours of the inspection with a verdict of Cleared to load, Hold or Not cleared. To add these checks, book an inspection.
Sources
- Commission Regulation (EC) No 552/2009, REACH Annex XVII entry 27 nickel (EUR-Lex)
- Commission Regulation (EU) No 836/2012, lead in jewellery, entry 63 (EUR-Lex)
- Commission Regulation (EU) No 494/2011, cadmium, entry 23 (EUR-Lex)
- Commission Communication C/2023/1604: standards under REACH entry 27 (EUR-Lex)
- ECHA: Substances restricted under REACH (Annex XVII)