Sterling silver is not automatically nickel-free: findings, solder and the nickel layer under plating are the usual sources. In the EU, REACH limits nickel release from jewelry that touches skin and restricts lead and cadmium; in the US, CPSIA applies to children's jewelry and California's Prop 65 requires warnings for lead and cadmium above set levels. The brand selling the product is legally responsible, so ask for test reports on your actual styles. This guide explains each rule and what a valid report looks like.
Part of our Jewelry Import Guides by Country
A retailer emails asking for your nickel release test report. You forward the request to your supplier and get back a photo of a certificate in Chinese, dated three years ago, for a product that is not yours. The retailer drops the order. This is the single most common way jewelry brands lose wholesale accounts they had already won.
Nickel, lead, and cadmium restrictions are the product-safety layer of the jewelry business, and unlike hallmarking or duty, they apply to what the metal actually is rather than to paperwork. As the party placing goods on the market, the brand carries the legal responsibility — not the factory. Deechy Jewelry Manufacturing & Design can arrange REACH testing at an extra cost, and this guide explains what each regulation requires and what a valid report looks like.
Nickel: The EU and UK Restriction
Nickel is regulated under REACH Annex XVII entry 27 because prolonged skin contact causes allergic contact dermatitis in a meaningful share of the population. The restriction is not a content limit — it is a release limit, measuring how much nickel migrates out of the article under simulated wear conditions.
| Article type | Nickel release limit |
|---|---|
| Post assemblies inserted into pierced ears or other pierced body parts | 0.2 µg/cm²/week |
| Articles in prolonged contact with skin (rings, bracelets, necklaces, watch cases, earring backs) | 0.5 µg/cm²/week |
The relevant test standards are EN 1811 for release measurement, EN 12472 for articles with a coating (which are subjected to simulated wear and corrosion first, then tested), and EN 16128 for eyewear. The EN 12472 detail matters more than it appears: a plated piece that passes the release test when new can fail after simulated wear, because the coating wears through and exposes the substrate underneath. If your product is rhodium-plated or gold-plated sterling silver, insist that the report cites EN 12472, not EN 1811 alone.
Sterling silver itself is an alloy of 92.5% silver and 7.5% other metals, most commonly copper. Nickel is not required in that alloy, and a properly formulated sterling alloy passes comfortably. Risk enters through components rather than the body of the piece — earring posts and butterfly backs, clasps, jump rings, chain findings, and any base-metal element in a mixed-material design.
Cadmium and Lead in the EU
Two further REACH entries apply directly to jewelry articles.
Cadmium is restricted under entry 23. Metal parts of jewelry articles must not contain cadmium at or above 0.01% by weight — that is 100 ppm. Cadmium historically appeared in low-grade solder and in some plating baths, which is why the restriction targets jewelry specifically.
Lead is restricted under entry 63. Jewelry articles must not be supplied to the public if the lead concentration in any individual part is at or above 0.05% by weight — 500 ppm — where that part may come into contact with skin during normal use. Lead appears in some solders and in certain crystal and glass components.
The UK operates a retained version of REACH post-Brexit with materially equivalent limits, so a product formulated for the EU market generally satisfies UK requirements as well.
The United States: CPSIA and Prop 65
US federal law approaches this differently, focusing on children's products rather than jewelry generally.
CPSIA sets a total lead content limit of 100 ppm for accessible parts of children's products, and a limit of 90 ppm for lead in surface coatings. Children's jewelry falls squarely inside this. If you sell any piece marketed to or designed for children under 12, you also need third-party testing by a CPSC-accepted laboratory and a Children's Product Certificate. This is a genuinely different compliance burden from adult jewelry, and it is worth deciding deliberately whether you want to be in that category.
ASTM F2923 is the standard consumer safety specification for children's jewelry, covering cadmium, lead, nickel, small parts, and other hazards. Retailers frequently require compliance with it even where it is not independently mandated.
California Proposition 65 is the rule that reaches adult jewelry. It requires a clear warning before knowingly exposing anyone in California to listed chemicals, and both lead and cadmium are listed. A body of jewelry-specific consent judgments has established material composition standards that most of the industry now treats as the practical benchmark. Because enforcement in California is driven substantially by private actions, this is an area where an untested product line represents real exposure for a US-selling brand.
What a Valid Test Report Contains
Most compliance failures are documentation failures rather than material failures. A report a retailer will accept has all of the following.
An accredited laboratory. SGS, Intertek, Bureau Veritas, TÜV, or an equivalently accredited body. A factory's internal test sheet is not a substitute.
Your specific article. The report should identify the tested sample in a way that maps to the style you are buying — a style code, a photograph, or a clear description. A generic report for "silver jewelry" tells a retailer nothing about the earrings in your box.
The right standard cited. EN 1811 or EN 12472 for nickel release, with EN 12472 required for coated articles. Content limits for cadmium and lead expressed in ppm or percentage by weight.
Component-level testing. On a mixed-material piece, the substrate, plating, solder joints, and findings can differ in composition. A report covering only the body of the pendant misses the clasp, which is often the actual risk.
A current date. Retailers commonly want reports within two or three years, and a new report is required whenever you change alloy, plating specification, or component supplier.
Designing the Problem Out
The cheapest compliance strategy is specification, not testing. Testing tells you whether you have a problem; specification prevents it.
Write nickel-free findings into your purchase specification explicitly, covering posts, backs, clasps, jump rings, and chain. Specify cadmium-free and lead-free solder. Where a piece is plated, specify a nickel-free barrier layer rather than the conventional nickel underlayer — this is the single most common hidden source of nickel in an otherwise compliant sterling piece, because the nickel sits invisibly beneath the finish and emerges as the plating wears. And specify plating thickness in microns, since a thicker layer takes longer to wear through to whatever lies beneath.
These specifications cost slightly more per piece at the factory. They cost far less than a recall, a delisted product, or a wholesale account that walks away.
Earrings and plated pieces are where nickel problems usually start, so compare finishes across our earrings and necklaces, such as this crystal necklace and bracelet set. The glossary defines nickel-free and REACH, and our guide to plating and anti-tarnish treatments covers barrier layers.
Frequently Asked Questions
Is sterling silver nickel-free?
Sterling silver is 92.5% silver alloyed with 7.5% other metals, usually copper, and does not require nickel. However, nickel commonly appears in findings such as earring posts, clasps and jump rings, and in the barrier layer beneath plating. The alloy being nickel-free does not mean the finished piece is.
What is the EU nickel release limit for jewelry?
0.5 µg/cm²/week for articles in prolonged contact with skin, and 0.2 µg/cm²/week for post assemblies inserted into pierced ears. These are release limits measured under EN 1811, with EN 12472 simulated wear applied first for coated articles.
Do I need CPSIA testing for adult silver jewelry?
CPSIA's children's product requirements apply to products designed or intended primarily for children 12 and under. Adult jewelry is outside that scope, though California Proposition 65 still applies to lead and cadmium exposure for products sold in California.
Who is legally responsible for jewelry compliance — the brand or the factory?
The party placing the goods on the market. For an imported product that is the importer or brand, not the overseas manufacturer. Supplier test reports are evidence supporting your compliance, but the legal obligation sits with you.
Can Deechy provide REACH test reports?
Yes. REACH testing, which covers nickel release and lead and cadmium limits for the EU, is available at an extra cost. Ask before ordering so testing can be planned alongside production.
Part of our Jewelry Import Guides by Country
This article is general information for wholesale buyers, not legal advice. Regulatory limits are amended over time — confirm current requirements for your market and product category before placing goods on the market.
