Why metal limits get mixed up

Export documentation for plated earrings and necklaces frequently lists “REACH compliant” without naming the annex entry or test method. In practice:

• Nickel is controlled primarily through release after abrasion preconditioning, not a simple percentage in the alloy certificate.
• Cadmium in jewelry metal is subject to a strict content limit in the finished metal part (not a release test in the same sense as nickel).
• Lead appears across several REACH and product-safety contexts; jewelry may be screened for total lead in metal or in surface coatings depending on article type and market.

A brass core with 0.3 µm gold plating can pass a total-cadmium digestion on the plated shell while still failing nickel release if the underplate or solder contains high-nickel alloy. Each metal answers a different lab question.

Nickel release under REACH Annex XVII

For articles intended for direct and prolonged skin contact, REACH entry 27 sets nickel release limits measured after standardized wear simulation (commonly EN 12472 abrasion followed by EN 1811 release testing):

• Piercing posts and assemblies: release not exceeding 0.5 µg/cm²/week.
• Other skin-contact jewelry (earrings, necklaces, rings worn against skin): release not exceeding 0.2 µg/cm²/week.

The test targets migration from the surface under sweat-simulating conditions, not the bulk nickel percentage in casting alloy. Stainless steel findings, white-gold-tone brass, and some solders are frequent contributors when release fails despite a “nickel-free” top plate.

Cadmium and lead: content limits vs coating risk

Cadmium in jewelry has been restricted under REACH entry 23 since 2011 for metal parts: cadmium content must not equal or exceed 0.01% by weight in the metal portion of jewelry and imitation jewelry articles. That is a bulk chemistry limit on the metal fraction, including base metal and findings, not a plated skin-contact release metric.

Lead restrictions depend on article classification. Metal jewelry components have been subject to tightening lead limits under REACH annexes addressing lead and its compounds in articles supplied to the general public, with additional attention when articles may be mouthable or accessible to children. Plated surfaces and low-melting solder joints are common lead hotspots in demi-fine construction because leaded brass and some brazing alloys still appear in legacy tooling inventories.

Reading lab data against the right limit

Technical files that hold up in audit separate metal, test, and article role:

Declare each field explicitly

• Base alloy grade for casting and findings (e.g., lead-free brass specification, sterling 925, solder alloy class).
• Plating stack thickness and metals in each layer (flash copper, nickel barrier, gold topcoat); nickel barrier layers affect release even when not customer-facing.
• Article contact class whether the tested SKU is piercing, earring hook, necklace chain against clavicle, or non-contact charm.
• Test citation annex entry, method (EN 1811/12472, ICP digestion for Cd/Pb), and which component was sampled (whole article vs finding lot).

Tests that answer different questions

• EN 1811 nickel release after EN 12472 abrasion: skin-contact risk for entry 27; unrelated to cadmium content.
• ICP/OES total element digest on metal shavings: cadmium and lead content against annex content limits.
• XRF screening on plated surface: fast inbound screening; may not replicate release or subsurface solder unless abraded.

Metal parameter map (indicative)

Demi-fine programs that substitute low-nickel barrier plates and lead-free solder before plating often see release and content metrics move together, but each still needs its own method line on the report. A single “heavy metals pass” line rarely substitutes for annex-specific results.

Takeaway

REACH metal rules for jewelry are not one combined score: nickel is judged by release after wear simulation, cadmium by metal-part content, and lead by content limits that depend on article type. Sound documentation names the alloy, plating stack, contact class, annex entry, and test method per component. When only a blanket compliance label appears on a spec sheet, the corrective path is method-specific retesting on the failing metal layer, not assuming a gold topcoat certificate covers nickel in the underplate or lead in the solder.