Jewelry that touches skin sold in the EU must pass the nickel release limit in REACH Annex XVII, and the United States and UK markets increasingly expect the same documentation even where the law is softer. Compliance is not a certificate in a drawer: it is a chain of test reports that matches the actual production batch. Buyers who collect the right documents at order stage never face a port-side recall.
What the law actually requires
The REACH nickel entry limits release to 0.5 micrograms per square centimetre per week for parts in direct and prolonged skin contact (posts, clasps, chains worn against skin) and 0.2 for pierced parts. The test method is EN 1811, with adjustments for plated items. Lead and cadmium restrictions under the same annex also apply and are the two other frequent failures.
Which documents to demand, and from whom
From the plating or materials supplier
Material declarations: plating chemistry, nickel-free base alloy specification, and EN 1811 test reports on the plated finish, not the bare metal. A report on raw brass is worthless once it is plated.
From the factory
A declaration of conformity naming the exact style numbers covered, plus batch test reports at least annually or whenever the plating supplier changes. Ask for the plating supplier’s name on the declaration, an anonymous certificate is not auditable.
For your own file
Keep the chain: your PO referencing the style, the factory declaration referencing the plating batch, the lab report referencing the test method. Retail customers and market surveillance authorities ask different questions, but the same chain answers both.
| Document | Covers | Renewal |
|---|---|---|
| EN 1811 nickel release report | Plated finish in skin contact | Annually or on supplier change |
| Lead and cadmium declaration | Base alloy and solders | Annually |
| REACH declaration of conformity | Finished style numbers | Per style |
| Plating supplier identity | Traceability | Per declaration |
Common failure patterns
The repeating story: the buyer tests the golden sample, the factory quietly changes plating suppliers to save cost, and the spring shipment fails a spot test. Prevent it with a written change-control clause: any change in plating or base material supplier requires notification and a new test report before shipment. It costs nothing to write and everything when ignored.
Frequently asked questions
Yes for stones sold as diamonds. IGI and GIA issue reports for lab-grown stones, and the report number is usually laser inscribed on the girdle.
Both are accepted in trade; IGI is the volume standard for lab-grown while GIA carries broader consumer recognition. What matters more is the process: match the laser inscription to the report at receipt, every stone, every delivery. The certificate without inscription matching is paper, not protection.
For parts in prolonged skin contact, yes in practice: the REACH nickel entry limits release, and EN 1811 is the reference method for plated items. Collect the report on the plated finish from the plating supplier, a declaration of conformity per style from the factory, and re-test when the plating supplier changes. Reports on bare metal are not evidence.
