Background

Due to several serious incidents that have occurred with lead-containing children’s products, France proposed a restriction on lead and lead compounds in jewellery under REACH Annex XVII and issued an Annex XV Dossier which was subject to a public consultation which ended in December 2010. Following the official process of implementing a new restriction, the Committee for Risk Assessment (RAC) and the Committee for Socio-economic Analysis (SEAC) issued a report with their opinions on the Annex XV dossier.

Proposal 

Both, RAC as well as SEAC agreed on the need to restrict lead under REACH Annex XVII. Even so, both committees have different proposals for the restriction:

RAC proposal:
Lead and its compounds shall not be used or placed on the market in:
       i) Metallic and non-metallic parts of jewellery articles if the lead concentration is equal to or greater than 0.05% by 
       weight of the part;
       ii) The paragraph above does not apply when it can be demonstrated that the rate of lead release from the jewellery 
       article or any part thereof does not exceed 0.05 μg/cm2/hr (0.05 μg/g per hr).

SEAC proposal:
Lead and its compounds:
1. Shall not be used or placed on the market if the concentration of lead is equal to or greater than
0.05% by weight of any individual part of the jewellery articles and hair accessories, including:
- bracelets, necklaces and rings, piercing jewellery, wrist watches and wrist-wear, brooches and cufflinks.

2. Paragraph 1 shall not apply to:
       i) “Full Lead Crystal” and “Lead Crystal” as defined in Annex I in Council Directive 69/493/EEC);
       ii) internal components of watch timepieces inaccessible to consumers;
       iii) non-synthetic or reconstructed precious and semiprecious stones (CN code 7103) unless they have been treated

       with lead or its compounds or mixtures contain these substances;
       iv) enamels defined as vitrifiable products resulting from the fusion, vitrification or sintering of minerals melted at a 
       temperature of at least 500 °C.

3. Paragraph 1 shall not apply to jewellery articles placed on the market before 12 months after the entry into force and jewellery articles produced before 10 December 1961.

The European Chemcal Agency (ECHA) will send these two opinions to the European Commission which will make the decision as whether to introduce the suggested restriction in Annex XVII of the REACH regulation.

Additional Information

Background document of RAC and SEAC:http://echa.europa.eu/doc/reach/restrictions/background_doc_lead_and_its_compounds.pdf

Contact Information
Bureau Veritas offers a wide range of chemical management solutions to help you overcome the
challenges of complying with the REACH Regulation. To find out how we can assist you in meeting
the requirements REACH poses to your business, visit www.bureauveritas.fr, www.bureauveritas.co.uk/cps or www.bureauveritas.de/cps.