ElanoryaReading the wording
In these texts, relief written for older articles carries a day inside its own sentence
A relief written for old articles is still written as a sentence, and the sentence carries a day. This page prints those sentences: two EU derogations, a further EU paragraph with a cut-off of its own, and — read separately, from US federal texts — a date of manufacture and a relief that names children’s metal jewelry inside its own exclusion list.
Where the idea of an age exemption comes from
The idea is not invented. Among the provisions read on this page, some lift a restriction for articles of a certain age or for articles that were already on the market before a given point, and one draws its own boundary at a date of manufacture. A reader who has met that idea has met something with a source in the wording of these provisions.
What the wording also contains is a day. In the EU derogations read here, the relief and the date are in the same sentence, and the date is attached to a specific event: the first time an article was placed on the market, the time it was produced, or a day on which an age is counted. On the US side, read separately and from different instruments, 16 CFR § 1303.1 attaches its ban to a date of manufacture, and 15 U.S.C. § 1278a(b)(7) writes its relief for used children’s products with an exclusion list inside it.
That is the whole of what this page reports: which sentence, which day, and which event the day is attached to. It reports the wording of these provisions and nothing about any particular article.
In the European Union: the lead derogation names two days
REACH Annex XVII entry 63 was added by Regulation (EU) No 836/2012. Its paragraph 5 reads: “By way of derogation, paragraph 1 shall not apply to jewellery articles placed on the market for the first time before 9 October 2013 and jewellery articles produced before 10 December 1961.”
The sentence names two groups of jewellery articles and joins them with “and”: articles placed on the market for the first time before 9 October 2013, and articles produced before 10 December 1961. This page goes no further than that wording — what paragraph 1 restricts is not opened here, and neither is the relationship between the two groups beyond the words the derogation uses.
Both days are days in the past that the text names. Neither is written as a period counted forward from the moment of reading, and neither is written as an age.
In the European Union: fifty years counted on 10 January 2012
Paragraphs 10 and 11 of REACH Annex XVII entry 23 were added by Regulation (EU) No 494/2011. Paragraph 11 reads: “By way of derogation, paragraph 10 shall not apply to articles placed on the market before 10 January 2012 and jewellery more than 50 years old on 10 January 2012.”
This is the one sentence in the EU material read here that contains a period of time as well as a day, and the two are written together. The fifty years are counted on 10 January 2012. The text names that day for the count and names no later day on which the count is taken again.
The same day appears twice in the same regulation. Article 2 of Regulation (EU) No 494/2011 reads: “It shall apply from 10 January 2012.” The day the restriction applies from and the day the age is counted on are, in this text, the same day.
Nothing here converts fifty years into a year of production. The count belongs to the sentence that states it, and this page performs no arithmetic on it.
In the European Union: the dates as the amending regulations print them
Taken from the Official Journal copies of Regulation (EU) No 836/2012 (which added entry 63), Regulation (EU) 2015/628 (which added paragraphs 7 to 10 of entry 63) and Regulation (EU) No 494/2011 (which added paragraphs 10 and 11 of entry 23), read on 20 August 2026.
| Provision | Day in the text | The event the day is attached to |
|---|---|---|
| Annex XVII entry 63, paragraph 5 (lead) | 9 October 2013 | Jewellery articles placed on the market for the first time before that day |
| Annex XVII entry 63, paragraph 5 (lead) | 10 December 1961 | Jewellery articles produced before that day |
| Annex XVII entry 23, paragraph 11 (cadmium) | 10 January 2012 | Articles placed on the market before that day |
| Annex XVII entry 23, paragraph 11 (cadmium) | 10 January 2012 | Jewellery more than 50 years old on that day |
| Annex XVII entry 63, paragraph 10 | 1 June 2016 | Articles placed on the market for the first time before that day; the paragraph this one lifts is not opened on this page |
In the United States: 16 CFR § 1303.1 names a date of manufacture
This block is read on its own, from US federal texts. Nothing in it is derived from the EU wording above, and nothing above is derived from it.
16 CFR § 1303.1 paragraph (b) reads: “This ban applies to the products in the categories described in paragraph (a) of this section that are manufactured after February 27, 1978…”. The boundary the section draws for itself is a date on which an article was manufactured. What the categories in paragraph (a) contain is not opened on this page.
Paragraph (a) also records that the figure it states was reduced with effect from August 14, 2009, as mandated by Congress in section 101(f) of the Consumer Product Safety Improvement Act of 2008. The figures themselves are outside what this page reports; the date is the part read here.
The section carries its own source note, which reads: “[42 FR 44199, Sept. 1, 1977, as amended at 73 FR 77493, Dec. 19, 2008]”. The dates in that note belong to the publication history of the rule, not to any article.
In the United States: the used-goods relief names children’s metal jewelry
The second US text read here is 15 U.S.C. § 1278a(b)(7). It states: “The lead limits established under subsection (a) shall not apply to a used children’s product.”
The relief is written around a defined term, and the definition in the same paragraph continues: “Such term shall not include— (i) children’s metal jewelry;”. The exclusion list is part of the relief’s own wording, and children’s metal jewelry appears in it as clause (i).
The Consumer Product Safety Commission states the same thing on its own page on total lead content: “Used children’s products (except children’s metal jewelry…) are not subject to the total lead content requirement per 15 U.S.C. § 1278a(b)(7).” The parenthesis continues with further items that are not opened on this page.
What a children’s product is, and how anything is placed inside or outside that term, is not covered here. This block reports only that the relief for used articles carries an exclusion list and that children’s metal jewelry is named in it.
What this page does not do, and what no Elanorya flow does
The boundary between reporting wording and doing something with it matters here, so it is written out rather than implied.
- This page reports the wording of the provisions named above. It does not evaluate any particular article, collection or transaction against any of them.
- It is not resale guidance, and it carries no instruction about what to do with any piece. No sentence here is addressed to a reader as a course of action.
- No Elanorya flow dates a piece, establishes provenance, determines when an article was first placed on the market, values a piece or evaluates any relief. The product does not do this at any level, and nothing on this page states or implies otherwise.
- No flow reads alloy, plating, coating or material composition from a photograph, and nothing in the product measures a threshold of any kind.
- No laboratory, testing, screening, appraisal or certification service is offered here or implied anywhere on this page.
- Elanorya is a visual tool that produces images from photographs. Nothing on this page is a claim about that product.
How this reading was taken, and what it does not cover
The EU side was read on 20 August 2026: REACH Annex XVII entry 63 and entry 23, in the published copies of the amending regulations — Regulation (EU) No 836/2012, Regulation (EU) 2015/628 and Regulation (EU) No 494/2011 — on EUR-Lex. The wording quoted above is the wording as those regulations published it. The consolidated Annex XVII text as it stands today was not verified: the consolidated file fetched on that day ended before Annex XVII was reached. Whether these paragraphs read identically today cannot be settled from this reading.
Paragraphs 11 to 14 of entry 63 were not fetched, and nothing on this page describes them or claims anything about the full extent of entry 63. The ECHA page listing substances restricted under REACH returned an HTTP 403 response and none of its content is used anywhere here.
The US side was read on the same day, 20 August 2026: CPSC’s own pages, opened in a browser, together with 16 CFR § 1303.1 and 15 U.S.C. § 1278a(b)(7). The code and statute text was read from the Cornell LII copy, because ecfr.gov redirected to a bot wall; no cross-check against eCFR or govinfo was possible, so these quotations cannot be confirmed identical to the official copies.
All of this is a reading taken on one day. Published pages and consolidated texts can change without notice, and this page is dated for that reason rather than maintained.
Questions
Does the fifty-year measure in the EU cadmium derogation move forward as time passes?
The wording added by Regulation (EU) No 494/2011 counts the age on a stated day: “jewellery more than 50 years old on 10 January 2012”. The count is taken on that day, and the text names no later day on which it is taken again. This page does not convert that count into a year of production.
Do the EU dates say anything about the United States, or the US dates about the EU?
No. The EU wording read here comes from EU amending regulations and concerns the EU restrictions; 16 CFR § 1303.1 and 15 U.S.C. § 1278a(b)(7) are US federal texts, read separately and in their own block. Neither reading is treated as evidence of the other. No third jurisdiction — the United Kingdom, Türkiye, Canada, China, Japan or Australia — is covered, and the US reading is federal-level only.
Does 16 CFR § 1303.1 name a date?
It names two. Paragraph (b) reads: “This ban applies to the products in the categories described in paragraph (a) of this section that are manufactured after February 27, 1978…”. Paragraph (a) records that the figure it states was reduced with effect from August 14, 2009, as mandated by Congress in section 101(f) of the Consumer Product Safety Improvement Act of 2008. What the section covers, and the figures it states, are not opened on this page.
Is the relief for used children’s products in 15 U.S.C. § 1278a(b)(7) written without exceptions?
The paragraph states: “The lead limits established under subsection (a) shall not apply to a used children’s product.” The definition in the same paragraph continues: “Such term shall not include— (i) children’s metal jewelry;”. CPSC’s page on total lead content states the same exclusion. What a children’s product is, and how anything is placed inside or outside that term, is not covered here.
Can Elanorya tell when a piece was made or when it was first placed on the market?
No. Elanorya produces images from photographs. No flow dates a piece, establishes provenance, determines when an article was placed on the market, values a piece or evaluates any relief, and no flow reads alloy, plating, coating or composition from a photograph.