Summary of Requirements:
Scope: Jewelry – The definition of jewelry in the new settlements is the same as the definition used in older settlements and in the California Jewelry law.
Review of Lead Requirements
- Previous settlements & California Jewelry law for adult jewelry - requires jewelry to be made out of Class 1, Class 2, and/or Class 3 materials
- Class 1
- Stainless or surgical steels, karat gold, sterling silver; platinum group metals, pearl, glass, ceramic, crystal and certain gemstones; and adhesives
- Natural decorative materials (bone, feathers, leather, shell, wood, etc.), elastic, fabric, ribbon, rope, and string with no intentionally added lead
- Class 2
- Surface coatings and dyes – Less than 600 ppm total lead (0.06%)
- Electroplated metal alloys – Less than 60000 ppm total lead (6%)
- Unplated metals – Less than 15000 ppm total lead (1.5%)
- Plastics or rubbers – Less than 200 ppm total lead (0.02%)
- Class 3
- All other materials which is not a Class 1 or Class 2 material – Less than 600 ppm total lead (0.06%)
- Previous settlements & California jewelry law for children’s jewelry
- Materials in Class 1 (see adult jewelry requirements above)
- Nonmetallic materials in Class 2 (see adult jewelry requirements above)
- Metallic materials that are not Class 1 – Less than 600 ppm total lead (0.06%)
- Glass or crystal decorative components – Less than 200 ppm total lead (0.02%) for components weighing more than 1 gram
- Printing ink or ceramic glaze – Less than 600 ppm total lead (0.06%)
- All other materials – Less than 200 ppm total lead (0.02%)
- Recent settlements for adult and children’s jewelry
- Surface coatings – 90 ppm total lead
- Substrates – 200 ppm total lead
Note: No warning labels are allowed by the California Jewelry law, the older existing settlements or the newer existing settlements. Reformulation is required by them all.
Major Points About New Limits
- The lead limit for all metal substrates in adult jewelry is significantly lower in the recent settlements in comparison to the limits in previous settlements
- 60000 ppm to 200 ppm total lead for electroplated metals
- 15000 ppm to 200 ppm total lead for unplated metals
- CPSIA
- Lead limits for accessible surface coatings of children’s jewelry under CPSIA are the same as recent settlements
- Lead limit for accessible substrates of children’s jewelry under CPSIA (100 ppm) is more stringent than recent settlements
- Lead limits of the recent settlements and the California Jewelry Law apply to inaccessible materials of children’s jewelry, however under CPSIA only materials that are accessible before and after use and abuse testing must meet the limits
Bureau Veritas Consumer Products Services, Inc. ("BVCPS") provides the information in this client bulletin as a resource of general information. It does not replace any applicable legal or regulatory requirements and is provided "as is." BVCPS will not be liable for any indirect, special, punitive, consequential or other damages (including without limitation lost profits) of any kind in connection with this client bulletin. BVCPS DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, IN CONNECTION WITH THIS CLIENT BULLETIN.
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A number of settlements involving lead in jewelry have been finalized recently. These settlements require the defendants to meet more stringent requirements than what is currently required by the California Jewelry law. Their requirements are also more stringent than the requirements of previous settlements.
