REACH and the European Nickel Release Standard
The EU REACH regulation (Annex XVII, Entry 27) limits nickel release from any product in prolonged skin contact to 0.5 micrograms per square centimeter per week. This is a release rate test, not a total nickel content test — pieces containing nickel in the alloy can still pass if the nickel is fully encapsulated by plating or surface treatment. Practical implication: a brass base with quality PVD or rhodium plating can legally enter the EU market, but worn-through plating that exposes the nickel-containing base will cause a piece to fail retesting.
Reputable manufacturers test every new design using EN 1811 (the standard REACH nickel release test) and retain reports for at least five years. Demand a current test report dated within the last 12 months for any new SKU destined for the EU, and budget 80 to 150 EUR per SKU for third-party testing through SGS, BV, or TUV if the factory cannot provide one.
CPSIA, California Prop 65, and US Standards
In the United States, the CPSIA (Consumer Product Safety Improvement Act) primarily regulates children's jewelry, defined as items designed or intended for children 12 and under. Total lead content must not exceed 100 ppm and total cadmium content in surface coatings must not exceed 75 ppm. For adult jewelry, state-level rules dominate — California, Minnesota, and several others have their own lead and cadmium caps that functionally apply to the national market.
California Proposition 65 is the most aggressive US regime. It does not ban substances, but it requires clear warning labels on products containing any of 900+ listed chemicals above safe-harbor levels, including lead, cadmium, nickel, and certain phthalates. Failure to label correctly has generated tens of thousands of settlement demands by private enforcers, typically costing 30,000 to 90,000 USD per case. If you sell into California at all (and you almost certainly do, via Amazon and Shopify), either ensure your products test under safe-harbor levels or display compliant Prop 65 warnings on packaging and listings.
What Test Reports to Demand from Your Supplier
Build a compliance document pack for every SKU before you accept first shipment. At minimum, request: an EN 1811 nickel release report for EU-bound pieces, an XRF screening or ICP-MS lab report for lead and cadmium content on surface coatings, a phthalate test if the piece contains any polymer components (cord, resin, silicone), and a material declaration listing every alloy and plating layer.
Store these reports by SKU number in a shared folder your team, freight forwarder, and customs broker can all access. When a shipment is stopped at the border — which happens more often than most buyers expect — having the test reports available within hours rather than days often determines whether goods clear customs or get destroyed. Compliance is not a one-time checkbox; it is an operational discipline that separates buyers who scale from buyers who get blindsided.
