ElanoryaEuropean Union — REACH Annex XVII, entries 63 and 23
The EU lead and cadmium figures are written into the parts, not into the finished piece
A seller lists one necklace. The lead paragraph is written about any individual part of it, and the entry defines that phrase itself. The cadmium paragraph sits in a different entry, with its own unit and its own scope, and the two are not one threshold.
The lead figure is written into a part
A seller assembles a necklace from a chain, a clasp and a cast element, photographs it, and lists it as one product. Entry 63 of Annex XVII to Regulation (EC) No 1907/2006 (REACH) — the lead entry — is not written about that product. Its first paragraph reads: “Shall not be placed on the market or used in any individual part of jewellery articles if the concentration of lead (expressed as metal) in such a part is equal to or greater than 0,05 % by weight.”
Two things in that sentence set the unit. The restriction lands on any individual part of jewellery articles, and the concentration it speaks of is the concentration in such a part. Both halves point at the same object, and neither points at the assembled piece.
The sentence is also written without a reader in it. It is phrased about placing on the market and use, and it is quoted here with that phrasing kept, in the wording published by Regulation (EU) No 836/2012, the regulation that inserted entry 63.
The figure itself is stated as 0,05 % by weight, with lead expressed as metal. That unit — a share of mass in a part — is the one used throughout this page, and the decimal comma is the source's own.
The entry defines both of the phrases it depends on
Paragraph 1 turns on two phrases, and paragraph 2 defines them rather than leaving them to ordinary usage.
The first: “‘jewellery articles’ shall include jewellery and imitation jewellery articles and hair accessories, including: (a) bracelets, necklaces and rings; (b) piercing jewellery; (c) wrist watches and wrist-wear; (d) brooches and cufflinks;”. Imitation jewellery is inside the defined term, and so are hair accessories, which a catalogue may file somewhere else entirely.
The second: “‘any individual part’ shall include the materials from which the jewellery is made, as well as the individual components of the jewellery articles.” This definition reaches in two directions at once. It covers the components — the clasp, the jump ring, the cast element — and it covers the materials those components are made from. It draws no line between metal and anything else.
Read together, the paragraph is about a part of an article that the entry has defined, at a concentration read in that part.
The derogations are drawn material by material
Paragraph 4 of entry 63 opens “By way of derogation, paragraph 1 shall not apply to:” and then names four things. None of the four is a product type: three are named as materials, one is named as components identified by accessibility, and one of them carries a condition about treatment.
- Crystal glass, by reference to a definition elsewhere
- “(a) crystal glass as defined in Annex I (categories 1, 2, 3 and 4) to Council Directive 69/493/EEC”. The derogation borrows its meaning from that Annex rather than describing the material itself.
- Watch internals that a consumer cannot reach
- “(b) internal components of watch timepieces inaccessible to consumers”. The qualifier is accessibility, written into the derogation.
- Natural precious and semiprecious stones, with a treatment condition attached
- “(c) non-synthetic or reconstructed precious and semiprecious stones (CN code 7103, as established by Regulation (EEC) No 2658/87), unless they have been treated with lead or its compounds or mixtures containing these substances”. The word unless is part of the derogation, not a footnote to it.
- Enamels, defined by how they are made
- “(d) enamels, defined as vitrifiable mixtures resulting from the fusion, vitrification or sintering of minerals melted at a temperature of at least 500 °C”. The definition is about fusion, vitrification or sintering and a temperature, not about appearance or use.
Cadmium is a separate entry with its own unit and its own scope
Cadmium is not a second figure inside the lead entry. It sits in entry 23 of the same Annex, and the jewellery paragraph read for this page is paragraph 10, in the wording published by Commission Regulation (EU) No 494/2011, the regulation that inserted it.
That paragraph reads: “Shall not be used or placed on the market if the concentration is equal to or greater than 0,01 % by weight of the metal in: (i) metal beads and other metal components for jewellery making; (ii) metal parts of jewellery and imitation jewellery articles and hair accessories, including: — bracelets, necklaces and rings, — piercing jewellery, — wrist-watches and wrist-wear, — brooches and cufflinks.”
Three differences from the lead paragraph are visible in the wording itself. The figure is 0,01 % and its unit is by weight of the metal, not simply by weight. The scope is written as metal beads, other metal components for jewellery making, and metal parts of the articles listed. And the extension to components is inside the paragraph itself rather than in a separate one.
The lead definition in entry 63 paragraph 2(ii) makes no metal distinction; the cadmium paragraph read here writes metal beads, metal components and metal parts. That is a difference in what the two texts say, and it is left at that: the paragraph read states a figure for the metal items it names, and this page derives nothing about anything it does not name.
Readings the wording does not carry
Each row pairs a reading these paragraphs will not carry with the wording that settles the point.
The two percentages are quoted together as a single EU heavy metal limit for jewellery.
They are separate figures in separate entries. Lead: 0,05 % by weight, in any individual part as entry 63 defines that phrase. Cadmium: 0,01 % by weight of the metal, in the metal items entry 23 paragraph 10 names. Neither is a stricter or looser version of the other, and they are not added or averaged.
The lead figure is described as a limit for a finished necklace or a finished ring.
Paragraph 1 states the concentration in such a part, and paragraph 2(ii) defines any individual part to include the materials the jewellery is made from as well as its individual components.
The derogation list is passed on as “stones and enamel are exempt”.
Paragraph 4 names non-synthetic or reconstructed precious and semiprecious stones under CN code 7103 with an unless clause about treatment with lead, and defines enamels by fusion, vitrification or sintering of minerals melted at a temperature of at least 500 °C.
A percentage is converted into another unit so it can be compared with a supplier's number.
The figures were read as published: 0,05 % by weight and 0,01 % by weight of the metal. No conversion into any other unit was performed for this page, and none is offered here.
A wholesaler's description of an item is treated as settling where a part stands against a figure.
The texts read state thresholds and contain no analytical standard, sample preparation protocol or laboratory method. Nothing on this page shows that any item meets or misses either figure.
What this reading does not settle
Bounded to the texts named in the last section, read on 20 August 2026.
- Jurisdiction: these are European Union texts. No threshold for any other jurisdiction is stated here, and no figure from anywhere else is presented as parallel to these.
- Measurement: the texts read give no analytical standard, no sample preparation protocol, no laboratory method and no measurement uncertainty, so how a concentration is determined is not something this page can report.
- Any particular item: whether a given part, component or finished piece stands above or below either figure is not determined here, and no supplier, importer or product is assessed on this page.
- Product capability: no Elanorya feature identifies materials, components, alloys or coatings in a photograph, and none can tell one part of a piece from another for any purpose. No laboratory, testing, screening or certification service is offered, arranged or implied.
- Marketplace effects: these are conditions on placing on the market and use. Nothing in the texts read connects a figure to search ranking, marketplace visibility, conversion, returns or buyer trust, and no such connection is drawn here.
Where this wording comes from, and how far it is dated
REACH Annex XVII entry 63 and entry 23, in the Official Journal texts of the amending regulations 836/2012 and 494/2011, read on 20 August 2026. Entry 63 paragraphs 1, 2, 3 and 4 are quoted from Commission Regulation (EU) No 836/2012; entry 23 paragraph 10 is quoted from Commission Regulation (EU) No 494/2011.
That is a specific kind of copy. These are the paragraphs as published by the regulations that inserted them, not a consolidated version of the Annex as it stands today; a consolidated text was sought for this reading and the part covering Annex XVII was not obtained. That the paragraphs read letter for letter the same today does not follow from this reading and was not verified for this page.
For the same reason, everything above is dated rather than standing. It reports what those published texts say, on the day named at the top of this page, and carrying it forward is a fresh reading rather than an inference from this one.
Two companion pages keep the same discipline on different material: one reads national ring size charts and reports that none of the sources read there defines a conversion between them, and one sets out what an image tool is instructed to do with a piece rather than what it can determine about it. Both are linked below.
Questions
A necklace is assembled from parts bought separately. What does the lead paragraph attach its figure to?
To any individual part of jewellery articles, with the concentration read in such a part. Entry 63 paragraph 2(ii) defines that phrase to include the materials the jewellery is made from as well as the individual components of the article, so the wording reaches the chain, the clasp and the cast element as parts rather than the assembled necklace as one object.
Are components sold loose, before anything is assembled, inside the same paragraph?
Paragraph 3 of entry 63 reads: “Paragraph 1 shall also apply to individual parts when placed on the market or used for jewellery-making.” In the text read, being unassembled is not a condition that changes which paragraph a component sits under.
Does the lead entry treat metal parts differently from stone, resin or enamel?
The definition in paragraph 2(ii) covers the materials from which the jewellery is made as well as the individual components, and draws no metal distinction. The four derogations in paragraph 4 are separate from that definition and are written material by material, one of them with a treatment condition attached.
Is an untreated natural gemstone covered by the derogation?
Paragraph 4(c) names non-synthetic or reconstructed precious and semiprecious stones under CN code 7103, “unless they have been treated with lead or its compounds or mixtures containing these substances”. The qualification is part of the derogation as written. Whether any particular stone answers that description is not something this page determines.
Can the lead and cadmium figures be quoted together as one EU limit?
They are written in different entries, in different units and over different scopes. Lead is 0,05 % by weight in an individual part as entry 63 defines that phrase; cadmium is 0,01 % by weight of the metal in metal beads and other metal components for jewellery making and in the metal parts of the articles entry 23 paragraph 10 lists. Neither is presented in the texts as a version of the other.
Can a photograph show which part is which, or what a part is made of?
No. No Elanorya feature identifies materials, components, alloys or coatings in a photograph, and none can separate one part of a piece from another for any purpose. These paragraphs are about concentrations determined by measurement, and this page reports their wording only.