REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is the EU’s central chemicals regulation, in force since 2007. It applies to almost anything placed on the EU market, not just raw chemicals, and puts the compliance burden on manufacturers and importers rather than on the substance itself being pre-approved by a regulator. General product safety, traceability and labelling sit in a separate regulation, the GPSR.
The Two Parts That Actually Matter for Merchandise
Most of REACH is about registering and evaluating industrial chemical substances, which is not something a merchandise buyer or producer deals with directly. Two parts of it are:
Substances of Very High Concern (SVHC). ECHA maintains a Candidate List of substances judged especially hazardous (as of 2026, 253 entries). If any listed substance is present in a product above 0.1 percent by weight, the manufacturer or importer has to notify customers and, for larger EU suppliers, register the article in the SCIP database. A customer can also ask directly, and the company has 45 days to answer. This applies across materials: plastics, printed textiles, coated metal, and packaging can all trigger it depending on what went into them.
Annex XVII restrictions. This is a list of specific substances that are banned outright or capped at a specific limit in specific product categories, decided case by case rather than as one blanket rule. Other Annex XVII entries beyond nickel cover things like phthalates in plasticised items, certain azo dyes in textiles, and lead or cadmium in various finishes, depending on what a specific product is made from. Toys have their own chemical limits under the EU toy safety rules, covered in our entry on EN 71.
The Nickel Restriction, Specifically
Nickel release from metal goods worn against skin (Annex XVII, entry 27) is the restriction most directly relevant to pins, medals, and other metal collectibles, and it is worth knowing in detail because it is easy to misread. The rule bans nickel entirely in post assemblies inserted into pierced ears and other pierced body parts, and separately caps nickel release from any item intended for prolonged direct skin contact at 0.5 micrograms per square centimetre per week (piercing post assemblies themselves are capped even lower, at 0.2). Compliance is verified using EN 1811, the standard reference test for simulating nickel release, with EN 12472 covering the accelerated wear and corrosion testing that plated items need first.
This is a release-rate restriction, not a nickel-content ban. A stainless steel item can contain roughly 10 percent nickel by weight and still pass comfortably, because the nickel stays locked in the alloy and barely migrates. A nickel-plated item with far less total nickel can fail the same test if the plating releases nickel faster than the limit allows. What a producer can put on a compliance certificate is the tested release rate, not a raw material percentage, and the two numbers do not predict each other. How this plays out for pins and keychains, together with the EU product safety rules, is covered in our guide to GPSR and nickel rules for metal pins and keychains.
What a Real Compliance Answer Looks Like
“REACH compliant” on its own is not a claim that means anything specific, since REACH covers dozens of unrelated restrictions across totally different materials. A producer who can name which SVHC or Annex XVII entries actually apply to a given product’s materials, and back that with lab test results where a numeric limit exists (nickel release being the clearest example), is answering the real question. A producer who can only offer the phrase “REACH compliant” with nothing behind it is not. For plated keyrings, our guide to custom keyrings for clubs and brands names the release test to ask for.
<nav class="article-breadcrumb"><a href="https://www.amball.com/magazine">Magazine</a><span class="article-breadcrumb__sep">/</span><a href="https://www.amball.com/glossary">Glossary</a><span class="article-breadcrumb__sep">/</span><span class="article-breadcrumb__current">REACH (EU Chemicals Regulation)</span></nav> <h1 class="article-h1">REACH (EU Chemicals Regulation)</h1> <p class="article-byline"><span class="cluster-badge">Licensing, Manufacturing & Compliance</span> · Updated September 24, 2026</p> <div class="article-intro"><p>REACH is the EU's core chemicals regulation, controlling which substances can be used in a product sold into the EU and how their presence has to be disclosed. For merchandise, the parts that matter most are the Substances of Very High Concern (SVHC) disclosure duty and specific Annex XVII restrictions like the nickel release limit on metal goods.</p></div> <ul><li>REACH is the EU’s core chemicals regulation (in force since 2007); the compliance burden sits with manufacturers and importers, not a pre-approval process.</li><li>For merchandise, two parts matter most: SVHC disclosure (any Candidate List substance above 0.1 percent by weight triggers notification and possible SCIP registration) and specific Annex XVII restrictions.</li><li>Nickel release from metal goods worn against skin is the Annex XVII restriction most directly relevant to pins and medals, but it is one entry among many, not the whole of REACH.</li></ul><p>REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is the EU’s central chemicals regulation, in force since 2007. It applies to almost anything placed on the EU market, not just raw chemicals, and puts the compliance burden on manufacturers and importers rather than on the substance itself being pre-approved by a regulator. General product safety, traceability and labelling sit in a separate regulation, the <a href="https://www.amball.com/glossary/gpsr">GPSR</a>.</p><h2>The Two Parts That Actually Matter for Merchandise</h2><p>Most of REACH is about registering and evaluating industrial chemical substances, which is not something a merchandise buyer or producer deals with directly. Two parts of it are:</p><p><strong>Substances of Very High Concern (SVHC).</strong> ECHA maintains a Candidate List of substances judged especially hazardous (as of 2026, 253 entries). If any listed substance is present in a product above 0.1 percent by weight, the manufacturer or importer has to notify customers and, for larger EU suppliers, register the article in the SCIP database. A customer can also ask directly, and the company has 45 days to answer. This applies across materials: plastics, printed textiles, coated metal, and packaging can all trigger it depending on what went into them.</p><p><strong>Annex XVII restrictions.</strong> This is a list of specific substances that are banned outright or capped at a specific limit in specific product categories, decided case by case rather than as one blanket rule. Other Annex XVII entries beyond nickel cover things like phthalates in plasticised items, certain azo dyes in textiles, and lead or cadmium in various finishes, depending on what a specific product is made from. Toys have their own chemical limits under the EU toy safety rules, covered in our entry on <a href="https://www.amball.com/glossary/toy-safety-testing-en71">EN 71</a>.</p><h2>The Nickel Restriction, Specifically</h2><p>Nickel release from metal goods worn against skin (Annex XVII, entry 27) is the restriction most directly relevant to pins, medals, and other metal collectibles, and it is worth knowing in detail because it is easy to misread. The rule bans nickel entirely in post assemblies inserted into pierced ears and other pierced body parts, and separately caps nickel release from any item intended for prolonged direct skin contact at 0.5 micrograms per square centimetre per week (piercing post assemblies themselves are capped even lower, at 0.2). Compliance is verified using EN 1811, the standard reference test for simulating nickel release, with EN 12472 covering the accelerated wear and corrosion testing that plated items need first.</p><p>This is a release-rate restriction, not a nickel-content ban. A stainless steel item can contain roughly 10 percent nickel by weight and still pass comfortably, because the nickel stays locked in the alloy and barely migrates. A nickel-plated item with far less total nickel can fail the same test if the plating releases nickel faster than the limit allows. What a producer can put on a compliance certificate is the tested release rate, not a raw material percentage, and the two numbers do not predict each other. How this plays out for pins and keychains, together with the EU product safety rules, is covered in our guide to <a href="https://www.amball.com/magazine/gpsr-nickel-metal-pins-keychains-eu">GPSR and nickel rules for metal pins and keychains</a>.</p><h2>What a Real Compliance Answer Looks Like</h2><p>“REACH compliant” on its own is not a claim that means anything specific, since REACH covers dozens of unrelated restrictions across totally different materials. A producer who can name which SVHC or Annex XVII entries actually apply to a given product’s materials, and back that with lab test results where a numeric limit exists (nickel release being the clearest example), is answering the real question. A producer who can only offer the phrase “REACH compliant” with nothing behind it is not. For plated keyrings, our <a href="https://www.amball.com/magazine/custom-keyrings-for-clubs-and-brands">guide to custom keyrings for clubs and brands</a> names the release test to ask for.</p> <section class="related-section"><h2>Related Glossary Terms</h2><div class="related-grid"><a href="https://www.amball.com/glossary/ppwr" class="related-card"><p class="related-label">Licensing, Manufacturing & Compliance</p><p class="related-title">PPWR (EU Packaging and Packaging Waste Regulation)</p><p class="related-snippet">PPWR (Regulation (EU) 2025/40) is the EU's Packaging and Packaging Waste Regulation, setting recyclability, recycled-content, and reporting rules for all packaging placed on the EU market, including merchandise items like hang tags, polybags, and shipping cartons.</p></a></div></section>
