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Advice or information on compliance issues does not carry any legal authority and does not replace the provisions of the legal regulations, only the regulations as interpreted by the courts have the force of law.
Why test for Nickel? Why test for Nickel?Nickel has been shown to be the most common cause of skin contact allergy in Europe. European Directive 94/27/EC was made UK Law in 2000 and specifies the upper limit for nickel release in articles which have direct and prolonged contact with the skin - such as Jewellery, fashion accessories, and metal adornments for apparel. It also specifies the upper limit for nickel content in specified articles.
Why are there 2 tests for Nickel Release?The DMG Swab Test was the initial regulatory test for the Danish and German Legislation. This became the basis for PREN12471 - The Scanning Nickel Release Test. However, it was considered to unreliable when used as a basis of prosecution not the least because it only gave a simple yes/no answer. The Commission asked for a quantitative method of testing which developed into the EN1811 Nickel Release and EN12472 Wear Test set of tests. The disadvantage with these tests is that they typically take 10 days to complete and are expensive when related to the cost of the item being tested, while industry needs a quick and cheap method of testing. Thus the DMG Swab Test was enhanced to allow industry to determine if items are likely to fail the nickel release threshold.
What should be tested?The ‘Nickel Directive’ 94/27/EC is clearly intended for items of Jewellery, watches and similar articles including fashion accessories worn close to the skin. It should not be forgotten that the first large scale sensitisation problems were associated with Nickel items in clothing. It is therefore necessary in showing due diligence under the various consumer protection legislation to test any metal items that the manufacturer or importer believes will come into direct and prolonged contact with the skin, for example. jeans studs, metal eyelets poppers on babies garments, belts, buckles on ladies shoes.
Can I just use the Swab test for Due Diligence?It is doubtful for the majority of Importers and manufacturers. The answer will have to wait until case law is made.
Should I do a separate 1811 Test as well as the 1811 & 12472 Set?Yes - Items have been found that pass the EN1811 Nickel Release Test after the EN12472 Wear Test but fail both the PREN12471 DMG Swab Test and the EN1811 Nickel Release Test on its own. This was due to surface contamination on the item which was worn off by the EN12472 Wear Test.
Does the Directive mean I can't use Nickel?The ‘Nickel Directive’ 94/27/EC does not ban the use of nickel per se. For the majority of items it only restricts the release of nickel ions from the item. Alloys that contain nickel that don't corrode, i.e. some stainless steels, don't release nickel ions and so may be used. It is also possible to barrier the release of nickel ions by using coatings and providing the barrier lasts for the equivalent of two years use that is also acceptable.
Does the Directive apply to Belts?It is the suppliers responsibility to decide whether any metal pieces on the belt will come into direct and prolonged contact with the skin.
For example belts designed to be worn through belt loops over the top of clothing are unlikely to come
into contact with the skin unless there is a large and/or ornate buckle, and the target market for the
belt is men with large beer belly's or pregnant women and thus may not need to comply.
A belt that is designed not to come into contact with the skin but is, however, normally worn in such
manner that the metal pieces on the belt will come into direct and prolonged contact with the skin, may
need to comply. However, there may be an element of consumer abuse available as a defence but this cannot
be relied upon as an absolute defence. Does the Directive apply to Brooches?The only part of a brooch that could normally come in direct and prolonged contact with the skin is the brooch pin. This would normally not happen on a heavy brooch or kilt pin as these items are expected to be warn on an outer garment with an other layer of cloth between the skin and the pin. It becomes more complicated on a light brooch as these may be worn with the pin touching the skin in which case the directive would apply to the brooch pin only.
What is Nickel Silver?Nickel Silver (also known as German Silver) is the generic name for any of a range of non-precious bright silvery-grey metal alloys, composed of copper, nickel and zinc. Despite its name it contains no silver.
Nickel Silver gets its name because its colour matches that of silver reasonably, and because it was
used as a low status substitute for silver in the 19th century. It is widely used for the commercial
production of industrial components, housewares, flatware and cutlery, and as the metal substrate for
silver-plated goods. The term EPNS stands for Electro-Plated Nickel Silver. |
| Page address http://www.teg.co.uk/nickel/faq.htm Last Updated 20th November 2003 |
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