GPSR for Jewellery: Nickel Release, Lead and Cadmium Limits (REACH) and Label Requirements

Which rules apply to jewellery

Earrings, necklaces, bracelets, rings, brooches, hair accessories and watches as fashion items are consumer products without a CE directive. The GPSR (Regulation (EU) 2023/988) sets their general safety requirement, and REACH (Regulation (EC) No 1907/2006) Annex XVII sets specific limits for nickel, cadmium and lead. Where EU law sets specific requirements, the GPSR covers the remaining aspects and risks (GPSR Article 2(1)).

A legal note. REACH is listed in Annex I of Regulation (EU) 2019/1020, which the GPSR uses to define “Union harmonisation legislation” (Article 3(27)). Some readers take this to mean that the GPSR manufacturer duties in Articles 9 to 18 do not apply to products restricted under REACH. The Commission's business guidelines (Notice C/2025/6233, section 2.2) nevertheless treat childcare articles and furniture, which REACH also regulates, as fully covered by the GPSR. The cautious approach, followed on this site, is to meet all GPSR duties for jewellery. This is an interpretation point, not a settled ruling.

Nickel release: REACH Annex XVII entry 27

Nickel is a common cause of contact allergy, so entry 27 restricts how much nickel an item may release. It is not a limit on nickel content.

Articles that do not meet these limits may not be placed on the market (paragraph 2), and conformity is shown with test methods adopted by CEN (paragraph 3). Your laboratory will name the current editions, including a wear simulation for coated items. Because release depends on the alloy and the plating, retest whenever the supplier, base metal or plating process changes.

Cadmium and lead: entries 23 and 63

Cadmium (entry 23, paragraphs 10 and 11): cadmium must not be used or placed on the market at 0.01% by weight of the metal or more in:

• metal beads and other metal components for jewellery making;
• metal parts of jewellery and imitation jewellery articles and hair accessories, including bracelets, necklaces and rings, piercing jewellery, wrist-watches and wrist-wear, brooches and cufflinks.

The exemption covers articles placed on the market before 10 December 2011 and jewellery more than 50 years old on that date.

Lead (entry 63, paragraphs 1 to 5): lead must not be placed on the market or used in any individual part of jewellery articles at 0.05% by weight or more. “Jewellery articles” include jewellery, imitation jewellery and hair accessories, among them bracelets, necklaces, rings, piercing jewellery, wrist watches and wrist-wear, brooches and cufflinks. “Any individual part” means the materials the jewellery is made from and each of its components. The same limit applies to parts sold for jewellery making (paragraph 3). Exemptions include crystal glass as defined in Directive 69/493/EEC, internal watch components inaccessible to consumers, natural or reconstructed precious and semi-precious stones unless treated with lead, and enamels (paragraph 4).

Because the lead limit applies part by part, a single low-cost clasp, solder joint or painted charm can make the whole piece non-compliant. Test each material and colour, not only the main body.

GPSR duties: risk analysis beyond chemicals

REACH covers the chemical limits; the GPSR covers everything else about safety. Under Article 9(2), carry out an internal risk analysis before placing the product on the market and keep technical documentation for 10 years (Article 9(3)). For jewellery it usually covers:

• Small parts and swallowing: beads, charms and stones that can detach, especially if children may use or play with the item;
• Magnets and button batteries: magnetic clasps or light-up pieces that a child could swallow;
• Strangulation: long necklaces and cords for children without a breakaway feature;
• Sharp edges and points on pins, earring posts and metal findings;
• Appeal to children: GPSR Article 6(1)(f)(ii) asks whether a product not designed for children is likely to be used by them, for example cartoon-themed adult jewellery, and Article 6(1)(e) asks you to assess the risk for vulnerable consumers.

Keep the nickel, cadmium and lead test reports in the technical documentation, linked to the batch or production lot they cover, together with supplier declarations. A supplier declaration alone is weak evidence if nothing links it to your parts. More on evidence in GPSR test reports and standards.

Working with jewellery suppliers: a practical control routine

Most jewellery sellers buy finished pieces or components from wholesale suppliers and change styles often. That makes supplier control the real compliance work. A routine that fits the REACH and GPSR rules above:

1. Write the limits into the purchase order. State the REACH Annex XVII requirements (entries 23, 27 and 63) and that they apply to every part, not just the finished piece. Ask the supplier to confirm the base metal, plating and solder for each style.
2. Ask for part-level evidence. A report on “zinc alloy, gold-plated” from another product line proves little. The report should name the parts, materials and colours that match your bill of materials.
3. Group styles sensibly. Where several styles share the same alloy, plating line and findings, one set of tests can cover the group if the lab agrees and the technical documentation explains why. New materials or colours need their own tests.
4. Retest on change. A new supplier, base metal, plating process or finding supplier is a new risk. Re-order runs from the same supplier can also drift, so spot-check periodically.
5. Give each production lot a batch number and record which test reports cover it. If an authority finds a problem, a batch number lets you limit the recall to the affected lot (see batch and serial numbers).
6. Keep the file for 10 years after the last item of that type is placed on the market (Article 9(3)).

None of this replaces the manufacturer's legal duty: if you sell under your own brand, you are the manufacturer under GPSR Article 3(8), even if a factory made the piece.

Labels for small items: what to put where

The GPSR traceability details must be on the product where possible, otherwise on the packaging or an accompanying document. Jewellery is a typical case where the item itself is too small:

• Type, batch or serial number (Article 9(5)): on the product if it can be easily visible and legible; otherwise on the backing card, bag or box, or an accompanying document.
• Manufacturer's name, registered trade name or trade mark, and postal and electronic address (Article 9(6)), plus the importer's details where there is an importer (Article 11(3)).
• EU responsible person (Article 16) if the manufacturer is outside the EU; see EU responsible person.
• Safety information and warnings in a language consumers easily understand (Article 9(7)), for example “not for children” on adult pieces with small parts or magnets, if your risk analysis calls for it.

Precious-metal hallmarking and fineness marks are not set by the GPSR; some Member States have national hallmarking laws, so check national rules if you sell gold or silver. A backing card layout with all GPSR fields can be drafted with the free tool at gpsrtools.com; general rules are in GPSR label requirements.

Online, Article 19 requires the offer to show the manufacturer's details, the responsible person's details if the manufacturer is outside the EU, a picture and product identifier, and any warnings or safety information.

Safety Gate: why jewellery keeps appearing and what to do

Safety Gate, the EU rapid alert system for dangerous non-food products, regularly publishes alerts on jewellery, often for lead, cadmium or nickel above the REACH limits. Authorities can order a withdrawal or recall, and the alert names the product, its brand and identifiers. You can search alerts by product category and risk type on the Safety Gate portal; see how to search Safety Gate alerts.

If you learn that a piece you sold exceeds a limit, the GPSR requires the manufacturer to take corrective action immediately and inform authorities through the Safety Business Gateway and consumers (Article 9(8)). Recall rules and the notice template are in accidents, recalls and Safety Gate.