Nickel content and nickel release are not the same question. For EU
market access, REACH Annex XVII Entry 27 restricts nickel release from
articles intended to come into direct and prolonged contact with human
skin.
The restriction is application-based. A metal buckle is not
automatically in scope merely because it contains nickel or has a
nickel-bearing coating. Buyers should first determine how the finished
product is used, who contacts it and for how long.
What Entry 27 says
For articles intended to come into direct and prolonged contact with
the skin, Entry 27 sets a nickel-release limit of 0.5 µg/cm²/week for
the relevant contacting parts. If a non-nickel coating is used, it must
keep release within the limit for at least two years of normal use. The
regulation lists examples such as jewellery, watch straps, fasteners,
rivets, zippers and metal marks used in garments.
The restriction also contains a lower limit for post assemblies
inserted into pierced parts of the body, which is generally not relevant
to pet, equestrian or webbing hardware.
A screening
decision before laboratory testing
| Question | Why it matters |
|---|---|
| Is the finished product a consumer product placed on the EU market? | Establishes the regulatory context |
| Is this hardware intended for direct human-skin contact? | The restriction is based on intended contact |
| Is the contact prolonged or repeated under normal use? | Brief incidental contact may be different from prolonged contact |
| Which surfaces actually touch skin? | Testing and material control should focus on relevant parts |
| Is the surface plated or coated? | Coating durability affects long-term release control |
| Could wear, sweat, cleaning or flexing expose another layer? | Normal-use ageing can change surface performance |
Pet collar hardware normally contacts the animal, not the owner’s
skin. A leash handle fastener, wearable bag fitting or garment buckle
may present a different scenario. Equestrian hardware can also vary: a
saddle fitting, rider-worn accessory and horse-blanket component do not
have identical contact conditions.
Specify release, not only
composition
A material declaration can identify alloy composition, but the legal
limit in Entry 27 is a release rate. Buyers who determine that the
restriction is relevant should specify the applicable test method,
sample preparation, ageing procedure for coated articles, surfaces to be
tested and pass/fail criteria with a qualified laboratory.
Do not accept “nickel-free” as an undefined marketing phrase. Ask
whether it means no intentionally added nickel, composition below a
stated threshold, or a nickel-release result under a named method.
Practical controls for OEM
projects
- Record the intended use and skin-contact assessment.
- Define the base material and complete coating stack.
- Approve a physical finish sample.
- Control pre-treatment and plating process parameters.
- Confirm whether ageing is required before release testing.
- Link the test report to the sample, drawing revision and production
batch. - Reassess when material, plating supplier or coating thickness
changes.
Jinxing Hardware can review material and surface-finish requirements
for custom hardware. Buyers remain responsible for determining
regulatory applicability and engaging an appropriate laboratory or
compliance adviser.
Frequently asked questions
Does REACH ban all nickel in metal hardware?
No. Entry 27 restricts nickel release for specified skin-contact
applications; it is not a general ban on all nickel-containing
metal.
Is a composition report enough?
Not when the requirement is a nickel-release limit. Composition and
migration are different measurements.
Are pet collar buckles automatically covered?
Not automatically. Applicability depends on the finished product’s
intended human-skin contact and use conditions. Obtain product-specific
compliance advice.
Sources
- ECHA, Annex XVII Entry 27 conditions: https://echa.europa.eu/documents/10162/3bbe9024-52a6-8e63-5581-e686331eb459
- European Commission, REACH restrictions: https://single-market-economy.ec.europa.eu/sectors/chemicals/reach/restrictions_en
- Consolidated REACH text: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006R1907-20241218
This article provides general information and is not legal
advice.
