What goes wrong

Nickel and cadmium, stated honestly

Updated October 2026

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Nickel So what does a nickel free claim mean here Cadmium We have not surveyed the state law Why stating the absence is useful What retailers ask for in practice References

There is no federal United States limit on nickel release from jewelry, and saying otherwise is the common error here.

Nickel

Nickel is a frequent contact allergen in jewelry and there is no federal United States restriction on nickel release from it. The European Union restricts nickel release in articles intended for prolonged skin contact under its own chemicals regulation, which is why nickel free claims are common on products made for both markets.

So what does a nickel free claim mean here

Whatever the seller means by it, which is the problem. With no federal definition, the claim is a marketing representation and sits under general truth in advertising principles rather than a numeric standard. If you make the claim, be able to say what test and what threshold you mean by it.

Cadmium

The CPSIA lead provisions are about lead. There is no general federal cadmium content limit for children’s jewelry equivalent to the 100 ppm lead limit. ASTM F2923, the consumer product safety specification for children’s jewelry, is a voluntary consensus standard that addresses cadmium among other hazards, and a number of states have legislated in this area.

We have not surveyed the state law

That is a deliberate omission, not an oversight. State jewelry metals statutes differ in scope, in the metals covered and in the age ranges they apply to, and a summary written without checking each one would be worse than no summary. Check the states you sell into.

Why stating the absence is useful

Because the two most expensive mistakes in this category are assuming a federal rule exists and assuming nothing applies. The first leads to testing you did not need, the second to a voluntary standard your retailer requires contractually and you have not met.

What retailers ask for in practice

Large retailers frequently require conformance to ASTM F2923 by contract, independent of federal law. If your route to market is through a chain, their vendor requirements may be a stricter and earlier constraint than anything in the CFR.

References

15 U.S.C. 1278a, Children’s products containing lead; lead paint rule. Total lead content by weight for any part of the product: 600 ppm, then 300 ppm one year after 14 August 2008, then 100 ppm three years after, unless the Commission determines 100 ppm is not technologically feasible for a product or category. The Commission is to review and revise the limit downward periodically. law.cornell.edu

15 U.S.C. 2052(a)(2), the Consumer Product Safety Act definitions as amended by the CPSIA. A children’s product is a consumer product designed or intended primarily for children 12 years of age or younger, determined by four factors: a manufacturer statement including a label if reasonable; representation in packaging, display, promotion or advertising; common recognition by consumers; and the Commission staff’s September 2002 Age Determination Guidelines. law.cornell.edu

Written from the CPSIA and the CPSC regulations, not from a bench. Whether a particular product is a children’s product is a determination on the facts of that product, and state law in this area has not been surveyed here. Nothing on these pages is advice on a specific item.