Rules
US lead and nickel limits for silver jewelry: what makers and sellers must know
What the CPSC requires for lead in children's silver and plated jewelry, why there is no federal nickel limit, and how to document alloys and finishes before you sell.
What to take away
- The federal lead limit applies to children's products. For accessible parts it is 100 parts per million (ppm) of total lead content, and children's metal jewelry is covered.
- Jewelry for adults has no mandatory federal jewelry-specific rule, according to the Consumer Product Safety Commission (CPSC). The agency points to voluntary ASTM standards instead.
- The CPSC jewelry guidance does not set a nickel-release limit. Nickel limits are a European Union matter that affects US sellers who ship to the EU.
- Solid sterling silver is treated differently from plated or mixed-metal pieces. A plated item is only as clean as its base metal and its solder.
- Whoever makes or imports a children's product must test it at a CPSC-accepted lab and issue a Children's Product Certificate.
Which jewelry counts as a children's product
The lead limit is written for children's products, so the first question is whether your piece is one. The CPSC defines a children's product as a consumer product designed or intended primarily for children 12 years of age or younger. Four factors decide it: the maker's stated intended use, including a label; how the product is packaged, displayed and advertised; whether consumers commonly see it as meant for that age group; and the CPSC's Age Determination Guidelines.
For jewelry, the CPSC says that jewelry intended for children is sized, themed and marketed for children. That makes your own listing text and photos part of the evidence. A silver charm bracelet with a cartoon animal, small sizing and a "gift for her little sister" description is easier to treat as a children's product than a plain cuff. If you keep your adult line adult in design and wording, you stay under the general-use rules. If you add a children's line, you move into the testing regime described below. Treat the two lines as separate product families with separate records.
The 100 ppm lead limit and who must test
Accessible components of children's products made in or imported into the United States must not contain more than 100 ppm of total lead content. The CPSC explains that this limit is in 15 U.S.C. 1278a. A component is inaccessible only if a sealed covering keeps it from being physically exposed, and the CPSC states that paints, coatings and electroplating do not make a part inaccessible. A silver or rhodium plating over a lead-bearing base does not solve the problem.
Children's metal jewelry sits in a stricter group. The CPSC's guidance for resellers says children's metal jewelry that does not comply with the 100 ppm limit cannot be sold, and that it must be tested for compliance. The used-product exclusion does not extend to children's metal jewelry.
Testing must happen at a third-party laboratory accepted by the CPSC. The agency lists the accepted test methods as CPSC-CH-E1001-08.3 for metal and CPSC-CH-E1002-08.3 for non-metal materials. Some X-ray fluorescence (XRF) technology is approved for certain homogeneous materials, with limits. The CPSC also notes that soluble lead testing for European requirements does not satisfy the CPSC.
The manufacturer or importer then issues a Children's Product Certificate (CPC). Under section 14 of the Consumer Product Safety Act and 16 CFR part 1110, the CPC must include seven elements, including:
- identification of the product,
- each applicable children's product safety rule,
- the certifier's name, address and phone number,
- contact details for the person who keeps the test records,
- the date and place of manufacture,
- the date and place of testing, and
- the name and contact details of the laboratory.
The CPC and the supporting test reports must be in English. Importers of most regulated consumer products must also electronically file certificate data with US Customs and Border Protection starting July 8, 2026, according to the CPSC page on certificates, so check the CPSC eFiling resources if you import.
Where sterling silver fits, and where plating does not
The CPSC's resellers guide gives a useful dividing line. It lists children's jewelry and other items made entirely of surgical steel, precious metals such as gold of at least 10 karat and sterling silver of at least 925/1,000, certain gemstones, or natural or cultured pearls as "OK to sell." The same table says children's metal jewelry in general should be tested, bought from a manufacturer who can show a test, or not sold.
The key words are "made entirely of." A solid sterling pendant on a sterling chain fits that description. A sterling pendant with a base-metal clasp, a soldered finding of unknown composition or a plated charm does not. Each accessible part is judged on its own, so one cheap component can put a whole piece out of compliance.
This is why the alloy records matter. If you cast, solder or finish your own pieces, note the alloy, the solder grade, the findings supplier and any plating. The article on silver alloys, fineness and composition explains how those variables differ, and the stock, hallmark and supplier batch record checklist shows what to write down. When a supplier gives you a test report, the CPSC allows a firm to rely on a supplier's results or certification if it uses due care, the testing is periodic, an accepted lab did it, and you can reach the underlying documentation under 16 CFR part 1109.
For resellers and thrift sellers, the same logic applies in reverse. A piece that looks like silver may be plate over a base metal, and the difference between sterling and silver plate is a practical question before you list anything marked for children.
What the CPSC says about adult jewelry and nickel
The CPSC's jewelry FAQ is short. It states that there are no mandatory federal requirements specifically for jewelry, and that voluntary consensus standards represent industry best practice: ASTM F2999 for adult jewelry and ASTM F2923 for children's jewelry. Children's jewelry falls under the rules for children's products, with total lead content and lead in paint and similar surface coatings given as examples.
That page does not mention nickel. Nothing in the CPSC pages reviewed for this article sets a federal nickel-release limit for jewelry, so a seller should not claim "meets US nickel limits." There is no such federal number to cite. A claim like "nickel safe" or "hypoallergenic" is a different matter. It is an advertising claim, and you should be able to support it with test results. The article on FTC rules for silver labeling covers how descriptions are treated as representations.
Nickel is regulated elsewhere. The EU restricts nickel in jewelry and other articles that touch the skin under entry 27 of Annex XVII to the REACH regulation, which sets release limits for items inserted into pierced skin and for items in direct and prolonged skin contact, and applies a two-year rule to coated items. If you ship to the EU, read the current entry itself rather than relying on a summary.
For makers who work mostly in sterling, the practical point is that the alloy is silver and copper by definition. Base-metal findings and plated components are where nickel usually enters a piece. Choose findings from suppliers who state their composition.
State rules to check
The CPSC notes that states such as Illinois and California have their own lead requirements. A seller who ships nationwide cannot assume that federal compliance ends the checklist. Look up the state rules for any state where you have a physical presence or sell in volume, using the state environmental or consumer protection agency as your source. This article did not review state statutes in detail.
