GPSR and REACH for Jewellery Sellers: 2026 Guide

If you sell handmade or small-batch jewellery on Etsy or Shopify and want to open the EU, two sets of rules meet on your workbench. GPSR decides who is responsible and what paperwork exists; REACH decides what may be in the metal. Most guides cover one or the other. This one covers both, in the order a jeweller actually needs them. It assumes you have read our general GPSR guide for Etsy sellers, which explains when GPSR applies and how to choose a Responsible Person.

Why jewellery is a “non-harmonised” product

Toys, electronics and cosmetics have their own EU laws with CE marking, declarations and test bodies. Adult jewellery has none of that. It is a non-harmonised product, which means the general safety net, GPSR, applies to it directly and completely. In practice that is simpler than CE, but it also means there is no template to copy: you build the technical file yourself.

Two consequences follow. First, you must not put a CE mark on jewellery. The mark is reserved for products covered by specific EU legislation, and placing it on an out-of-scope product is an offence in most member states. Second, the moment a piece is designed for a child under 14 to play with, it stops being jewellery and becomes a toy, with CE marking, EN 71 testing and a Declaration of Conformity. The test is “play value”, not the age of the wearer, so avoid words like “kids”, “children” or “toy” and child models in listings for adult pieces.

What GPSR asks of a jeweller

The five obligations are the same as for any product, but jewellery has its own answers.

GPSR obligation	What it means for jewellery
Responsible Person in the EU	A written mandate with an EU-based company or person; their name and postal address on your packaging and listing
Technical file and risk analysis	One file per model, kept 10 years: materials by component, supplier documents, test reports, risk table
Traceability	A batch number that the buyer can find, plus your name, postal address and email
Labelling and language	Information on the product where possible; a hang tag or insert card where the piece is too small, in the buyer’s language
Accident reporting and recall	Severe allergic contact dermatitis or an infection from an earring post is the typical reportable event

Jewellery has one practical advantage: the Commission’s guidelines accept that information can move from the product to the packaging when the product’s size makes marking impossible. An earring genuinely is too small. Aesthetics are not an accepted reason, but size is.

The risk analysis for a typical piece has these rows: nickel allergy, cadmium and lead exposure, small parts that can be swallowed, sharp points on posts or wire ends, breakage and choking hazard from chains and beads, strangulation for necklaces, and infection from non-sterile posts. Each row gets a likelihood, a severity and the measure you take, which is where the REACH tests come in.

REACH: the chemical limits that apply anyway

REACH Annex XVII applies independently of GPSR and has applied for years. The three entries that matter for jewellery:

Entry	Substance	Limit
27	Nickel, post assemblies inserted into pierced ears or other pierced parts	Release below 0.2 µg/cm² per week
27	Nickel, articles in direct and prolonged skin contact (necklaces, bracelets, rings, watch cases)	Release below 0.5 µg/cm² per week
27	Nickel, coated articles	The limit must still be met after two years of normal use, simulated by EN 12472 wear and corrosion before the EN 1811 release test
23	Cadmium in metal parts of jewellery	Below 0.01% by weight
63	Lead in any accessible part of jewellery	Below 0.05% by weight

Note the wording. Nickel is a release limit, measured by the EN 1811 test in artificial sweat. It is not a content limit, so a cheap XRF scan that reports “nickel: 0%” says nothing about compliance. XRF is a legitimate screening tool for cadmium and lead content, but it cannot replace EN 1811 for nickel.

Cubic zirconia is a synthetic stone. The exemption that natural gemstones enjoy under the lead entry does not extend to CZ, so a CZ-set piece is tested like any other metal article.

Where nickel actually comes from

The base of sterling silver is usually copper, not nickel. Nickel enters through three doors:

Solder. Low-melting-point solders often contain nickel. Every joint on a piece is a potential release point.
Plating baths. A nickel strike layer under rhodium or gold plating is common practice in the industry because it improves adhesion. It is invisible on the finished piece and it is exactly what EN 12472 wear testing is designed to expose.
Ear backs and findings. Spring-steel butterfly backs and some bought-in findings are nickel-bearing.

This is why you cannot describe a piece as “nickel-free” on the strength of the silver alloy alone. Without a written confirmation from your plater and a test report or supplier declaration for solder and findings, the claim is unsupported, which is a problem under Etsy’s policies and under consumer law.

Testing without breaking the bank

The big laboratories do not publish prices; everything is a quote. For orientation, a nickel package (EN 1811 plus EN 12472) with cadmium and lead on one sample runs around €240 per sample plus an order fee, takes three to four weeks, and needs at least five finished pieces per sample. Pricing is per component: post, butterfly, pendant, chain and clasp are each a sample.

Test material flows, not designs. A collection of forty designs might use only five material flows: one silver alloy, one type of ear post and back, one plated finish, one solder, one family of bought-in findings. Test those five once, roughly €1,200 in a single order, and every design made from them is covered. Retest only when you change supplier, alloy or plater. Testing each design separately is the mistake that makes GPSR look unaffordable.

Ask suppliers first. Reputable findings suppliers and platers already hold REACH test reports. A report is usable in your technical file if it covers the material you actually buy and is traceable to it. Start there; test only what nobody can document.

Labelling a piece that is too small to mark

Three pieces of print cover most collections:

Hang tag: brand, product name, model or batch code, material line (“925 sterling silver, 14k gold plated”).
Box label or insert card: the compliance block. Manufacturer with postal and email address, EU Responsible Person with postal and email address, and the batch number. A 40 x 25 mm thermal label in 5 to 6 point type is enough; a label printer costs under €200.
Care and warning card: “Not suitable for children under 14”, allergy note if any component is nickel-bearing, care instructions, in the languages of the countries you ship to.

On language: instructions and safety information must be in the language set by each member state. Germany’s Product Safety Act, in force since 19 February 2026, requires German. Starting with Ireland and Malta, which accept English, removes the translation burden while you set up.

Claims that get sellers into trouble

Do not write	Why
“Nickel-free” or “hypoallergenic” without a test or supplier declaration	Unsupported claim; Etsy policy and consumer law
“Vermeil” for thin plating	There is no legal UK or EU definition, but the trade benchmark is sterling silver base and at least 2.5 microns of gold; the US FTC rule uses the same figure. Under that, say “gold plated 925 sterling silver”
“Diamond” or “diamond-like” for cubic zirconia	Material misdescription; synthetic stones must be described as such
CE mark on packaging	Jewellery is out of scope; marking it is an offence
“Kids”, “children”, “toy”	Pulls the piece into toy legislation with CE, EN 71 and DoC

The UK side: no Responsible Person, but hallmarking and UK REACH

In Great Britain the UK General Product Safety Regulations 2005 apply and there is no EU-style Responsible Person requirement. UK REACH carries the same nickel, cadmium and lead limits as the EU version, so a piece that passes in one market passes in the other on chemistry. Northern Ireland follows EU GPSR.

What is different is hallmarking. Describing an item as gold, silver, platinum or palladium in the course of business is illegal unless it carries a UK hallmark, except below the exemption weights: 1.0 g for gold and palladium, 0.5 g for platinum and 7.78 g for silver. Weight is assessed per single article, so one stud earring counts on its own. Chains and pendants sold as one item are where sellers cross the line without noticing. Foreign assay marks, including Turkish fineness marks, are not recognised in the UK. Online sellers must also display the Dealer’s Notice (the online version is Dealer’s Notice B), which the Assay Offices provide free of charge; the fine for not displaying it can reach £5,000.

Cost and timeline for a small collection

Item	First year	Following years
EU Responsible Person	€150 to €1,200	Same, annually
REACH tests, five material flows	€800 to €1,500	Only when materials change
Technical file	Your own time, or a paid template around €400	Updates
Label printer and consumables	About €200	About €50
Multilingual insert cards	About €100	About €100
Total	€1,200 to €2,500	€300 to €650 a year

Tests take three to four weeks, supplier documents two to four weeks, a Responsible Person contract about a week, labels one to two weeks. Run in parallel, plan for two to three months, and open EU shipping only when everything else is done.

Frequently asked questions

Does GPSR require lab tests for jewellery?

GPSR requires a risk analysis and evidence that the product is safe; it does not name a test. REACH sets the nickel, cadmium and lead limits, and a lab report or a traceable supplier declaration is the practical way to show you meet them.

Can I use my supplier’s REACH report instead of testing?

Yes, if the report covers the exact material you buy and can be traced to it. Most reputable findings suppliers and platers hold one. Test only what nobody can document.

Is an XRF scan enough?

For cadmium and lead content it is a reasonable screen. For nickel it is not: the legal limit is a release rate measured by EN 1811 in artificial sweat, not a content figure.

Do I need a CE mark on jewellery?

No, and you must not add one. CE is reserved for products covered by specific EU laws. Adult jewellery is not; children’s play jewellery is, as a toy.

Do hallmarking rules apply to my EU sales?

UK hallmarking applies to items sold as precious metal in the UK. EU countries have their own rules; several accept the UK hallmark under the International Convention, but check the destination country before describing an item as silver or gold there.

How long does it take to be ready?

Two to three months if you request supplier documents in week one and run testing, the Responsible Person contract and label design in parallel.

General information, not legal advice

This guide summarises the rules as of September 2026. Confirm your own situation with a lawyer or your Assay Office before making claims or opening EU sales.

Before you open the EU, check that your prices carry the Responsible Person, testing and labelling costs with the Etsy fee calculator. If you want your listings, claims and pricing reviewed together, the Etsy Shop Audit covers all three.

GPSR and REACH for Jewellery Sellers: Nickel, Cadmium, Lead and the Paperwork (2026)