{
  "type": "problem",
  "slug": "jewellery-nickel-lead",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/jewellery-nickel-lead/",
  "markdown": "https://www.conphora.com/solutions/problem/jewellery-nickel-lead.md",
  "title": "We sell jewellery: what are the nickel and lead limits?",
  "description": "REACH limits for jewellery: nickel release for piercing posts and skin contact, lead 0.05 % per part, cadmium 0.01 % in metal parts, and what to test.",
  "answer": "Jewellery sold in the EU must meet the REACH Annex XVII restrictions: nickel release limits for piercing posts and items in prolonged skin contact (entry 27), lead below 0.05 % in any individual part (entry 63) and cadmium below 0.01 % in metal parts (entry 23). Sort the range by contact type and get test results per part. The GPSR's risk analysis, documentation and address duties apply alongside.",
  "theme": {
    "id": "chemicals-materials",
    "label": "Chemicals and materials"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    },
    {
      "id": "importer",
      "label": "Importer"
    },
    {
      "id": "online-seller",
      "label": "Online seller"
    }
  ],
  "regulations": [
    "REACH",
    "GPSR"
  ],
  "path": [
    "regulation-library",
    "knowledge-articles"
  ],
  "trigger": "A marketplace, a retailer or an authority asks for nickel, lead or cadmium test reports for earrings, necklaces, bracelets, watches or hair accessories",
  "keep": null,
  "why": [
    {
      "text": "Jewellery has no product-specific harmonisation act, but its chemistry is regulated in detail. REACH, Regulation (EC) No 1907/2006, says that a substance in an article for which Annex XVII contains a restriction shall not be placed on the market unless it complies with the conditions of that restriction (Article 67(1)). Three entries in Annex XVII matter most for jewellery: nickel (entry 27), lead (entry 63) and cadmium (entry 23).",
      "sources": [
        1
      ]
    },
    {
      "text": "The nickel entry works on release, not content. Nickel shall not be used in post assemblies inserted into pierced ears and other pierced parts of the body unless the release rate is less than 0.2 μg/cm²/week. In articles intended for direct and prolonged contact with the skin, such as earrings, necklaces, bracelets, chains, anklets, finger rings, wrist-watch cases, watch straps and metal parts on garments, the release from the parts in contact may not exceed 0.5 μg/cm²/week. A non-nickel coating must keep release within that limit for at least two years of normal use (entry 27, point 1). Such articles may not be placed on the market unless they conform, and the CEN standards are the test methods (points 2 and 3).",
      "sources": [
        1
      ]
    },
    {
      "text": "Lead and cadmium are limited by content. Lead shall not be placed on the market or used in any individual part of jewellery articles if the concentration is 0.05 % by weight or more (entry 63, point 1). Jewellery articles include imitation jewellery and hair accessories, and any individual part includes the materials and components the jewellery is made of (point 2); parts sold for jewellery making are covered too (point 3). Crystal glass, inaccessible watch components, untreated precious stones and enamels are exempted (point 4). Cadmium shall not be used or placed on the market at 0.01 % by weight of the metal or more in metal beads and components for jewellery making and in metal parts of jewellery, imitation jewellery and hair accessories (entry 23, point 10).",
      "sources": [
        1
      ]
    },
    {
      "text": "The General Product Safety Regulation (EU) 2023/988 applies alongside these restrictions. Where Union law sets specific safety requirements, the GPSR applies to the aspects and risks those requirements do not cover (Article 2(1)). Economic operators may only place safe products on the market (Article 5), and the safety assessment takes into account the categories of consumers, in particular children (Article 6(1)(e)). The manufacturer carries out an internal risk analysis and draws up technical documentation before placing jewellery on the market (Article 9(2)), and the importer checks that this has been done and adds its own name and address (Article 11(1) and (3)). REACH is one of the acts listed in Annex I to Regulation (EU) 2019/1020, to which the GPSR's definition of Union harmonisation legislation refers (Article 3(27)). The Commission nonetheless reads the GPSR as applying fully to everyday goods such as furniture and childcare articles that REACH also restricts (Commission Notice C/2025/6233, section 2.2), and Conphora follows that reading.",
      "sources": [
        2,
        4,
        5
      ]
    }
  ],
  "steps": [
    {
      "name": "Sort the range by how it touches the body",
      "text": "Separate items inserted into pierced ears or other piercings from items in direct and prolonged skin contact, such as necklaces, rings, bracelets, watch straps and metal parts on garments. The nickel limits differ between the two groups, and coated items have their own rule.",
      "item": "regulation-library"
    },
    {
      "name": "Check nickel release, not nickel content",
      "text": "Nickel is limited by its release rate: below 0.2 μg/cm²/week for piercing posts and not above 0.5 μg/cm²/week for parts in prolonged skin contact. A coating must keep release at or below 0.5 μg/cm²/week for at least two years of normal use. CEN standards are the test methods."
    },
    {
      "name": "Check lead and cadmium in every part",
      "text": "Lead may not reach 0.05 % by weight in any individual part of a jewellery article, including beads and components sold for jewellery making. Cadmium may not reach 0.01 % by weight of the metal in metal parts and metal beads. Check the listed derogations, such as crystal glass and enamels for lead.",
      "item": "knowledge-articles"
    },
    {
      "name": "Get test reports per material and model",
      "text": "Ask suppliers for test reports that name the model, the part tested and the method. Where several items share the same alloy or plating, record why one report covers them. Test again when the supplier changes alloy, plating or factory."
    },
    {
      "name": "Check the other risks under the GPSR",
      "text": "Jewellery has no product-specific harmonisation act. The REACH restrictions apply alongside the General Product Safety Regulation, so manufacturers and importers follow both: the restriction, and the GPSR's risk analysis, technical documentation, identification and address duties (Articles 9 and 11). The GPSR's general safety requirement also covers risks REACH does not, such as small parts children could swallow."
    }
  ],
  "documents": [
    {
      "name": "Nickel release test reports for piercing posts and skin-contact parts",
      "from": "A laboratory, through the supplier or your own order",
      "ground": "Regulation (EC) No 1907/2006 Annex XVII entry 27, points 1 to 3"
    },
    {
      "name": "Lead and cadmium content test reports per part",
      "from": "A laboratory",
      "ground": "Regulation (EC) No 1907/2006 Annex XVII entry 63, points 1 to 3; entry 23, point 10"
    },
    {
      "name": "Internal risk analysis and technical documentation",
      "from": "The manufacturer",
      "ground": "GPSR Articles 5 and 9(2)"
    }
  ],
  "risks": [
    {
      "title": "Non-conforming jewellery may not be placed on the market",
      "text": "Articles covered by the nickel restriction shall not be placed on the market unless they conform to the release limits (REACH Annex XVII entry 27, point 2), and a substance in an article restricted in Annex XVII may only be placed on the market if it complies with the restriction (REACH Article 67(1)).",
      "source": 1
    },
    {
      "title": "Lead in any single part is enough",
      "text": "Lead shall not be placed on the market or used in any individual part of jewellery articles at 0.05 % by weight or more, and that includes the materials and components the jewellery is made of (REACH Annex XVII entry 63, points 1 and 2).",
      "source": 1
    },
    {
      "title": "Penalties are set nationally",
      "text": "Member States lay down penalties for infringements of REACH, which must be effective, proportionate and dissuasive (REACH Article 126).",
      "source": 1
    }
  ],
  "faq": [
    {
      "q": "Do hair accessories and watches count as jewellery?",
      "a": "For lead, yes: jewellery articles include hair accessories, wrist watches and wrist-wear, brooches and cufflinks (REACH Annex XVII entry 63, point 2). Internal watch components inaccessible to consumers are exempted (point 4(b)). For nickel, wrist-watch cases, straps and tighteners are listed (entry 27, point 1(b))."
    },
    {
      "q": "Does 'stainless steel' mean nickel-free?",
      "a": "Not by itself. The nickel entry limits the rate of nickel release from the parts in contact with skin, whatever the alloy (REACH Annex XVII entry 27, point 1). Only a release test shows whether a part meets it."
    },
    {
      "q": "We sell vintage jewellery. Do the limits apply?",
      "a": "The lead limit does not apply to jewellery placed on the market for the first time before 9 October 2013 or produced before 10 December 1961 (entry 63, point 5). The cadmium limit does not apply to articles placed on the market before 10 December 2011 or to jewellery more than 50 years old on that date (entry 23, point 11). Cadmium in the brazing of a silver bracelet counts towards the limit for metal parts (Case C-512/24)."
    },
    {
      "q": "We sell loose beads for jewellery making. Are they covered?",
      "a": "Yes. The lead limit also applies to individual parts placed on the market for jewellery making (entry 63, point 3), and the cadmium limit covers metal beads and other metal components for jewellery making (entry 23, point 10)."
    },
    {
      "q": "Are precious stones covered by the lead limit?",
      "a": "Non-synthetic or reconstructed precious and semi-precious stones are exempted, unless they have been treated with lead or its compounds (REACH Annex XVII entry 63, point 4(c))."
    }
  ],
  "sources": [
    {
      "title": "Regulation (EC) No 1907/2006 (REACH), Annex XVII (consolidated text of 22 June 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006R1907-20260622",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529",
      "accessed": "2026-10-04"
    },
    {
      "title": "Judgment of the Court of 1 August 2025, BÁV, Case C-512/24",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62024CJ0512",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2019/1020 on market surveillance and compliance of products, Annex I (consolidated text of 12 August 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812",
      "accessed": "2026-10-04"
    },
    {
      "title": "Commission Notice — Guidelines on the application of the EU general product safety legislative framework by businesses (C/2025/6233)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/eli/C/2025/6233/oj",
      "accessed": "2026-10-05"
    }
  ],
  "related": [
    "marketplace-listing-removed",
    "test-purchase-failed",
    "product-on-safety-gate",
    "label-no-eu-address",
    "furniture-general-safety"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-05",
  "notice": "General information, not legal advice."
}