RAC and SEAC Recommendations to ECHA
Two European agencies, the Committee for Risk Assessment (RAC) and the Committee for Socio-Economic Analysis (SEAC), have finalized their opinions on France’s proposal to the European Chemical Agency (ECHA) to restrict lead content in jewelry. France initially proposed that the European Union (EU) adopt a lead limit of 0.09 μg/cm²/hr.
The RAC opinion would impose a restriction on lead in jewelry using a method similar to that recommended by the recently published ASTM Children’s Jewelry Safety Standard (ASTM F2923-11) for cadmium. Jewelry importers and producers would be required to meet a total content limit of 0.05% (500ppm) lead in metal and plastic components or demonstrate a migration rate of less than 0.05 μg/cm²/hr. Comments on the proposal led RAC to conclude that migration testing could also reference lead release in terms of μg/g/hr to avoid the difficulty of determining the surface area of a jewelry piece.
The SEAC recommends a rule for lead in jewelry that is based only on total content, due to the fact that total content testing will already be required in Europe for cadmium in jewelry articles by the time a new amendment for lead comes into effect. (Cadmium in jewelry is limited to 100ppm [0.01%] starting December 10 of this year.) The suggested limit is 0.05% (500ppm) and includes exemptions for lead crystal, vitreous enamels, internal components of watches, and precious and semi-precious stones. SEAC lead recommendations are proscriptive, not retroactive, allowing sell through of inventory brought to market up to one year after the regulations come into force. Jewelry over 50 years old would not be restricted. Both groups’ adopted opinions will apply to all jewelry, with no exclusions for adult products or precious jewelry.
The European Chemical Agency (ECHA) is currently developing its proposal pursuant to the two published opinions (RAC adopted 3/11/11; SEAC adopted 9/15/11) for inclusion into REACH Annex XVII.