REACH and nickel release.

Stainless steel is not nickel-free. Both 304 and 316L contain nickel — roughly 8–10.5% and 10–14% respectively — and any supplier who tells you otherwise is either mistaken or hoping you will not look it up.

What is regulated is not the nickel content. It is the rate at which nickel escapes the surface onto skin, and that is a different measurement entirely.

The rule, precisely

In the EU, nickel release from articles in prolonged skin contact is governed by REACH Annex XVII, entry 27 — the provision that replaced the older Nickel Directive. Two limits apply to jewelry:

The test method is EN 1811: the piece is immersed in an artificial sweat solution for a week, and the solution is then analysed for nickel. Results are expressed as release per unit area per week, which is why a small earring post and a wide bangle are judged against different thresholds.

There is a screening method, EN 12472, used for coated items — it simulates two years of wear before the release test, so a coated piece is judged on the surface it will have after wear, not the pristine one. If your product is PVD-coated, that pre-wear step is the relevant part.

Why this is a finished-product test

A common misunderstanding: a mill certificate for 304 or 316L sheet says nothing about nickel release. It certifies composition, not surface behaviour.

What changes the release rate is the surface:

• Polish grade. A rougher surface has more real area and releases more.
• Coating. A PVD layer is a ceramic compound that contains no nickel, so a coated surface releases differently from a bare one — but the test is still on the finished piece, because edges, holes and engraved areas may be uncoated.
• Edges and recesses. Coating coverage is never perfect at a sharp edge. That is where a release test will find what a specification claims does not exist.

This is why responsible suppliers test the actual product rather than quoting a material grade and moving on.

What testing costs and how long it takes

Typical figures from accredited laboratories — SGS, Intertek, Bureau Veritas, TÜV — for EN 1811 on jewelry:

A range with three finishes and two materials is not one test. It is commonly several, and a buyer planning a launch should budget for that rather than discover it at the end.

How to handle this as a buyer

If compliance matters for your market, ask these four questions and expect four specific answers:

1. "Which standard, and which version?" EN 1811 with the pre-wear step for coated items. An answer of "we comply with EU standards" is not an answer.
2. "Is the report on the finished product, or on the material?" Only the first one is useful to you.
3. "What is the sample date, and does it match our specification?" A report from three years ago on a different finish does not cover your order.
4. "Who pays for testing, and when?" Any supplier who will not state this up front is likely to raise it after you have committed.

Our position, stated plainly

We can arrange EN 1811 testing on request. Testing is a laboratory cost that is quoted separately and agreed before it is incurred — we will not add it to a unit price without telling you, and we will not produce a document we do not have.

What we can tell you without a test is the specification: 304 or 316L, stated on the quote; PVD coating with no nickel in the colour layer; and a retained reference piece per approved run. What we cannot tell you honestly is that a piece has passed a test we did not run on it.

If you need a current report for a specific SKU, say so at the brief stage. It adds one to two weeks to the timeline and it is far cheaper to plan for than to discover at customs.

The other documents buyers ask for

Nickel release is the one with a specific test. The rest are declarations, and they are worth understanding as a group:

• REACH SVHC declaration. A statement about substances of very high concern above 0.1% by weight. This is a declaration about materials, and it can be given on the basis of supplier declarations rather than testing.
• GPSR — the General Product Safety Regulation. Applies to consumer products sold in the EU from December 2024. It is about documentation, traceability and an identified EU responsible person, not about a laboratory result.
• California Proposition 65. A warning-based regime rather than a limit-based one. In practice it is a labelling question for your market, not a manufacturing one.

None of these substitute for each other, and a buyer who asks for "REACH compliance" as a single item usually needs two or three of them. Being able to name which is which is a reasonable proxy for whether a supplier has actually dealt with EU customers before.