We sell jewellery: what are the nickel and lead limits?

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).^[1]

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).^[1]

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).^[1]

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.^[2][4][5]