Nickel release is the compliance question metal trim suppliers are asked most often, and the one most often answered badly. It is not difficult. It does, however, require evidence at the level of the individual article and finish, and a clear understanding of what the test does and does not show.
What the rule says
In the EU, nickel is restricted under REACH Annex XVII, entry 27. Articles intended to come into direct and prolonged contact with the skin must not release more than 0.5 µg/cm² per week of nickel. The entry names “buttons, tighteners, rivets, zippers and metal marks, when used in garments” among the articles covered [1][2]. Where a nickel-containing article has a coating, the coating must keep nickel release within the limit for at least two years of normal use [1].
Great Britain kept the same restriction under UK REACH, so the requirement is effectively the same for UK and EU-bound garments [3]. Many US brands apply equivalent limits through their own restricted substances lists, even though there is no equivalent federal law.
For trims, the restriction is most relevant to:
- jeans buttons and rivets, especially the inside of the cap and the post, which sit against the skin;
- snaps on garments worn close to the body, such as babywear, shirts and lingerie;
- metal zips, sliders and pullers on garments where they touch the skin;
- metal marks, eyelets and hooks.
The test methods
EN 1811:2023 is the harmonised reference method for measuring nickel release from articles in prolonged skin contact [2]. In outline, the relevant surface of the article is immersed in an artificial sweat solution for one week, and the nickel released is measured and expressed per square centimetre of skin-contact area. The standard includes rules for interpreting the result against the limit that take account of measurement uncertainty, so a laboratory report should state a conformity decision, not only a number.
EN 12472 simulates wear and corrosion on coated items before they are tested to EN 1811. If your article has a nickel-containing base or under-plate beneath a nickel-free top coat, the brand will expect EN 12472 pre-treatment followed by EN 1811, because the question is whether nickel will reach the skin after use, not whether a new part releases it on day one.
Spot tests using dimethylglyoxime (DMG) are useful for quick screening in the factory or on receipt of goods. They are not a substitute for an accredited EN 1811 report.
Where suppliers go wrong
From the compliance team’s side of the table, these are the most common problems:
- Testing the alloy, not the article. A report on a brass coupon does not cover an antique-brass four-part snap. Brands want reports by article and finish.
- Ignoring the plating structure. Many decorative finishes, including some gunmetal, black nickel and antique effects, depend on nickel under-plates. If you do not know the layer structure, you cannot answer the brand’s questions.
- Skipping EN 12472 for coated parts. A new coated part can pass EN 1811 and fail after wear.
- Using out-of-date reports. Most brands expect reports to be renewed within a set period, often 12 months, and after any change to material, plating or sub-supplier.
- Loose use of “nickel-free”. If marketing says “nickel-free” and the technical team means “complies with 0.5 µg/cm²/week”, the brand will notice. Define the term and use it consistently.
- Choosing an unsuitable laboratory. Use a laboratory accredited to ISO/IEC 17025 with EN 1811 within its accreditation scope, and one the brand accepts.
The evidence a brand expects
| Evidence | What good looks like |
|---|---|
| Article and finish list | Every metal article that can touch skin, with base alloy, plating layers and finish codes |
| EN 1811 reports | One per article and finish (or a justified grouping agreed with the brand), from an accredited laboratory, in date |
| EN 12472 + EN 1811 reports | For coated items over nickel-containing bases |
| Material declarations | From alloy and plating sub-suppliers, stating nickel content or absence |
| Change control | A written procedure: any change to alloy, plating bath, layer structure or sub-supplier triggers notification and re-test |
| Screening records | DMG spot-test records for incoming materials and production lots, if you use them |
Designing out the risk
The most reliable route is to remove nickel where skin contact is likely. Common approaches include nickel-free alloys and plating systems for skin-contact parts, designs that keep the nickel-bearing component away from the skin, and finishes chosen with the brand’s technical team at the development stage rather than substituted later. Each option has cost, appearance and durability trade-offs, so agree the specification in writing and test the finished article.
How this fits into nomination
Nickel compliance alone will not win a nomination. It is, however, one of the first things a compliance team checks, and a gap here can end the conversation before the technical team sees your product. A supplier who arrives with an article-level test matrix, a clear plating specification and a one-page change-control procedure signals that it controls compliance, not merely that it passed a test once. That is the signal compliance teams are looking for.
Checklist for this week: list every skin-contact metal article and finish; mark which have a current EN 1811 report from an accredited laboratory; mark which coated items also need EN 12472; and write down who must be told, and when, if a plating sub-supplier changes its process.
This article is practical guidance, not legal advice. Regulations and brand requirements change. Confirm current requirements and test methods with an ISO/IEC 17025-accredited laboratory.
Sources
- European Chemicals Agency, substances restricted under REACH (Annex XVII, entry 27 nickel): https://echa.europa.eu/substances-restricted-under-reach
- SGS, EU harmonises EN 1811:2023 for nickel restriction under REACH (January 2024): https://www.sgs.com/en-ch/news/2024/01/safeguards-0224-eu-harmonizes-en-1811-2023-for-nickel-restriction-under-reach
- Health and Safety Executive, UK REACH: https://www.hse.gov.uk/reach/