A wholesale buyer ships 500 pairs of 925 silver earrings to Germany. Two weeks later the listing is pulled: an EU customs lab measured nickel release above the limit and the batch is refused entry. The factory claims we always use 925, but standard sterling made from secondary scrap can carry 0.05–0.2 percent residual nickel — enough to trip the regulatory threshold on ear wires and ring shanks. For any brand selling skin-contact jewelry into the EU or UK, the alloy spec has to be written down, not assumed. Here is the rule, the alloys that satisfy it, and the test numbers to ask for.

The regulation in plain terms

The EU Nickel Directive (2004/96/EC), now folded into REACH Annex XVII entry 27, sets two limits for articles intended to come into direct and prolonged contact with skin: 0.5 micrograms per square centimeter per week for nickel release from posts (ear wires) and other piercing parts, and 0.2 micrograms per square centimeter per week for items such as rings, bracelets, and necklaces that have a nickel-containing layer. The testing method is EN 1811, which includes a correction factor EN 12472 for coated items. The European Chemicals Agency (ECHA) publishes the most recent guidance and enforcement FAQs. Most importers ask for an EN 1811 test report per alloy batch, not a generic hypoallergenic claim.

Which silver alloys actually pass

Standard 925 sterling (Ag 92.5 percent, Cu 7.5 percent) cast from primary-refined silver and electro-copper passes if the incoming metal is traceable, but secondary scrap can push nickel above 0.05 percent. For EU-bound orders we specify either: (a) Certified 925 with declared nickel under 0.01 percent — primary-only feedstock, mill certificate on every lot. This is the cheapest compliant route and covers 90 percent of our EU orders. (b) Nickel-free sterling with zinc or tin replacements — typically Ag 92.5 percent, Cu 5–6 percent, Zn/Sn 1.5–2.5 percent. These alloys cast clean, polish well, and are explicitly tested by the alloy producer to EN 1811. (c) Argentium-style germanium-bearing silver — naturally low in nickel, slower to tarnish, and roughly 20–30 percent more expensive per gram. We do not use German silver or nickel silver — that is a copper-nickel-zinc alloy with no silver and is non-compliant for skin contact. Fineness marking rules for silver alloys are set by ISO 9202, and US marking rules by the FTC Jewelry Guides (see Sterling silver, Wikipedia).

Why plating is not a loophole

Buyers sometimes assume a thick rhodium or gold flash seals the nickel in. The regulation explicitly covers nickel-containing layers beneath a coating because scratches wear through the plating within months. The EN 12472 pre-treatment artificially ages the coating before testing. We apply the same reasoning we describe in electroplating thickness and wear: a 0.5–1 micrometer rhodium layer is cosmetic, not a compliance barrier. The base alloy must itself pass.

How EN 1811 testing works

The EN 1811 method immerses a test specimen in a synthetic sweat solution for one week at body temperature, then measures dissolved nickel by atomic absorption or ICP. The result is reported in micrograms per square centimeter per week, normalized to the exposed surface area. For plated items, EN 12472 first accelerates wear by tumbling the piece through a simulated abrasion cycle, which strips a fraction of the coating so the test measures what the skin actually sees after months of contact. Buyers should note that a fresh piece may test below the limit on day one, but after the EN 12472 wear cycle the base alloy exposure pushes the number up — this is exactly why plating alone does not satisfy the directive. We ask the lab to run both the direct EN 1811 and the EN 12472 pre-treatment version on the first batch.

Documentation we supply

For EU orders we hand over (1) the alloy mill certificate listing Ni, Pb, Cd values, (2) an EN 1811 test report from an accredited lab on the first production batch, and (3) a Declaration of Conformity naming the REACH entry. We also photograph the stamps and keep a sample per lot for two years. Our general QC flow is described in the jewelry order QC checklist and our photo log in QC photos before shipment.

Does 925 silver always contain nickel?

No. Primary-refined 925 can be essentially nickel-free. The risk comes from scrap-based secondary alloy. Ask for a mill certificate listing Ni under 0.01 percent.

Do I need a test report for every order?

Not for every reorder from the same alloy lot, but EU customs can ask for the most recent EN 1811 report. We re-test annually and on any alloy supplier change.

Is hypoallergenic a legal claim in the EU?

No. It is a marketing term with no regulatory definition. The enforceable numbers are the nickel release limits in micrograms per square centimeter per week.

Shipping silver jewelry into the EU or UK? HOLYCOME casts EU-compliant 925 from certified primary feedstock and supplies EN 1811 reports with every first-batch order. Ask about our nickel-free OEM program — send us your target markets and we will quote the right alloy and the test pack.

Frequently Asked Questions

How do I prevent sterling silver from tarnishing in storage?

Use anti-tarnish bags with a sulfur absorber, keep humidity under 60% and avoid paper wrapping. Rhodium plating adds a further barrier on high-turn SKUs.

Is rhodium plating worth the added cost?

Yes for display and gift lines. It resists tarnish for 12–18 months and keeps shelf pieces bright, which reduces markdowns.

What purity do you supply?

925 sterling silver, stamped and hallmarked. Fine silver (.999) is available for beads and bullion-style pieces.

What is the MOQ and lead time?

50 pieces per design, samples 3–5 days, bulk 15–20 days.