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Nickel Irritation and Skin Hazards – Understanding REACH Annex XVII Requirements

Nickel irritation is something you may have experienced yourself. Nickel is indeed a common metal used in our everyday lives’ products and materials, like in jewelry, apparel, hardware, electronics, alloys, plating, stainless steel, etc. It provides strength, corrosion resistance, and a bright metallic finish. However, nickel can also create health concerns when it is released from a product surface and comes into contact with the skin.

Nickel

Why does Nickel Cause Irritation?

Nickel is well known as a cause of allergic contact dermatitis. For people who are sensitive to nickel, skin contact with nickel-releasing items may cause irritation, itching, redness, rash, or eczema-like symptoms. The risk is higher when the contact is repeated, prolonged, or occurs in areas where sweat and friction are present.

A key compliance point is that REACH Annex XVII does not focus only on how much nickel is present in the material. The main concern is nickel release. This means a product may contain nickel but still comply if the nickel release rate is below the legal limit. On the other hand, a product with a small amount of nickel may still fail if nickel is released too easily from the surface. The Nickel Institute also notes that the potential for nickel allergy is linked to the quantity of nickel released, not only the nickel content.

REACH Annex XVII to Fight Nickel Irritation of the Skin Exposure

REACH Annex XVII Entry 27 applies to nickel and nickel compounds in specific product categories, including:

  • Articles inserted into pierced ears or other pierced parts of the body;
  • Articles intended to come into direct and prolonged contact with the skin;
  • Coated articles where the coating is intended to prevent nickel release.

Examples may include earrings, necklaces, bracelets, rings, zippers, buttons, rivets, clothing fasteners, and other accessible metal parts.

Products or parts

Why it may be a concern

Jewelry such as rings, bracelets, necklaces, anklets, earrings, and chains

These are classic examples of direct and prolonged skin contact.

Metal buttons, rivets, zippers, belt buckles, and garment fasteners

These can touch the skin through clothing openings or during wear, especially on jeans, jackets, belts, or uniforms.

Spectacle frames and sunglasses with nickel-containing metal parts

Frames touch the nose, ears, and temples for long periods; there is a dedicated nickel-release test method for spectacle frames and sunglasses.

Installation hardware such as clamps, thumb screws, brackets, knobs, and metal latches

If installers must repeatedly hold, tighten, or adjust exposed nickel-coated parts, direct and prolonged skin contact may be foreseeable.

Nickel Irritation when Direct and Prolonged Skin Contact

Not every nickel-containing component automatically falls under the restriction. The product’s use must be considered.

For example, an internal metal screw or a PCB inside a sealed electronic device may not be relevant if the user cannot access it during normal use. However, a metal watch back, earbud surface, necklace clasp, or eyeglass frame may require evaluation because it can touch the skin repeatedly.

Companies should review:

  • Whether the metal part is accessible;
  • Whether it touches the skin directly;
  • How often and how long contact occurs;
  • Whether sweat, wear, or friction may increase nickel release;
  • Whether the part is coated, plated, or bare metal.

Applicable Nickel Release Test Standards

Nickel release testing is typically performed using harmonized European standards. These include EN 1811 for nickel release from post assemblies and skin-contact articles, and EN 12472 for accelerated wear and corrosion simulation for coated items.

Using the correct test method is important because nickel release depends on actual surface behavior, not only material composition. A reliable compliance assessment should review both product construction and the intended use of the article.

How Enviropass can Help Manufacturers Design Products without Risks of Nickel Irriation

Enviropass supports companies with product environmental compliance, including EU RoHS, REACH SVHC, and Prop 65, as well as restricted substance assessments, supplier documentation review, and regulatory compliance strategy. For nickel-related REACH Annex XVII concerns, Enviropass can help determine whether your product may fall within the scope of Entry 27 and what evidence may be needed to support compliance.

Our team can assist with:

  • REACH Annex XVII applicability review
  • Nickel risk assessment for accessible metal parts
  • Supplier declaration and technical documentation review
  • Test plan development and integration of nickel controls into broader compliance programs.
  • Coordination of applicable testing through qualified laboratories
  • Compliance support for electronics, consumer products, apparel accessories, and industrial components

 

For companies managing complex bills of materials (BOMs) or global supply chains, Enviropass can help simplify the compliance process and identify risks before products reach the market.

FAQs on Nickel Irritation

Does nickel irritate skin?

Yes. Nickel can irritate the skin of people who are sensitive or allergic to it. This is commonly called nickel allergy or nickel contact dermatitis. It may happen when nickel-containing items, such as jewelry, watches, buttons, zippers, eyeglass frames, tools, electronics, or metal accessories, remain in direct contact with the skin.

Nickel can irritate skin because small amounts of nickel may be released from metal surfaces, especially with sweat, moisture, friction, or prolonged contact. In sensitive individuals, the immune system recognizes nickel as a trigger and causes an allergic skin reaction. This is why regulations such as EU REACH Annex XVII Entry 27 focus on nickel release, not only on whether nickel is present in the material.

Nickel is regulated because it can cause allergic contact dermatitis in sensitive individuals. Skin contact with nickel-releasing items may lead to irritation, itching, redness, rash, or eczema-like symptoms, especially when contact is repeated, prolonged, or occurs with sweat and friction.

Companies should assess whether the product has metal parts that are accessible, touch the skin directly, and are used repeatedly or for a prolonged period. They should also consider whether sweat, friction, coatings, plating, or wear may increase nickel release.

Supplier documentation helps companies understand the materials, surface finishes, coatings, and potential nickel-containing parts in a product. Reviewing supplier data can help identify compliance risks before products are placed on the EU market.

Yes. Compliance depends on how much nickel is released from the product surface, not only the total nickel concentration in the material. A low-nickel material may still be a concern if nickel is easily released during skin contact.

Nickel compliance helps companies reduce regulatory risk and improve product safety by limiting user exposure to nickel-releasing articles. It also supports REACH Annex XVII compliance for products that may come into direct and prolonged contact with the skin.

Conclusion about Nickel Irritation

Nickel is not completely prohibited under REACH, but its release is restricted for products that may expose users through skin contact. For compliance purposes, the most important factor is not only nickel content, but also how much nickel is released from the article during use.

By applying REACH Annex XVII, using appropriate European test standards, and maintaining strong supplier and testing documentation, companies can reduce the risk of nickel-related skin hazards and demonstrate compliance for products placed on the EU market.

About Enviropass

Enviropass offers practical support to help businesses understand nickel requirements and prepare documentation, enabling companies to better protect users and support compliance in the EU market.

For more information, please contact Enviropass.