The GPSR risk assessment for handmade jewellery

Article 9(2) of the GPSR wants an "internal risk analysis" before you sell. Fine. But nobody tells a jewellery maker which risks they are supposed to be analysing, so people either write "the necklace might break" and call it done, or freeze because they are not toxicologists.

Neither is necessary. For jewellery the hazard list is short, well understood, and mostly comes down to what your metal is made of. Here is the list, the numbers behind each item, and a completed assessment you can pattern-match against.

What a risk assessment is for

It is the working, not the conclusion. You are showing that you identified the realistic ways your product could harm someone, judged how bad and how likely each one is, and did something specific about it. It then feeds two other things: the risk analysis section of your technical file, and the warnings you put on your labelling and in Etsy's safety information field.

Same principle as the technical file: proportionate to the product. A pair of plain silver studs does not need what a battery-lit resin pendant needs.

The hazards that actually apply to jewellery

1. Nickel release

The big one, and the one with a hard legal number. Nickel is the most common contact allergen in Europe, and REACH Annex XVII entry 27 restricts how much can migrate out of anything in prolonged contact with skin:

0.2 µg/cm²/week for post assemblies inserted into pierced ears or other pierced body parts.
0.5 µg/cm²/week for everything else in direct and prolonged skin contact: rings, bracelets, necklaces, watch straps, clasps, chains.

The reference test method is EN 1811, updated to the 2023 version. Where an item is coated or plated, EN 12472 simulates wear and corrosion first, on the reasonable theory that plating wears off.

What this means in practice for a small maker: you are not expected to run a lab yourself. You are expected to know what your metal is and have evidence. A written supplier declaration for the alloy, kept on file, is normal and acceptable. Test reports are stronger, and worth having for a bestseller.

Watch your findings, not just your headline metal. Sterling silver components with cheap base-metal clasps, jump rings or ear wires are the classic failure: the piece is "silver", the part actually sitting in someone's earlobe is not.

2. Cadmium and lead

Two more REACH restrictions, both about the alloy or the plating rather than anything you do:

Cadmium, entry 23: restricted in jewellery to below 0.01% by weight.
Lead, entry 63: restricted in accessible parts of jewellery to below 0.05% by weight.

Cheap cast metal components, especially imported charms and pendants, are where these turn up. Again, supplier material certificates are the practical evidence. If a supplier cannot tell you the composition of what they sold you, that is your answer about the supplier.

3. Small parts and choking

Any component that can detach and fit in a small child's mouth: clasp springs, beads, charms, crimps, decorative stones.

For an adult product, the assessment is usually that the item is not intended for children, plus a warning to keep it away from them. For anything aimed at or likely to be used by children, this becomes a design constraint rather than a warning, and it is worth applying the small-parts cylinder test from EN 71-1 even though, as covered below, your product may not legally be a toy.

4. Strangulation and entanglement

Cords, ribbons, long chains, anything worn around the neck by a child. Length and breakaway behaviour are the variables. A breakaway clasp on a children's necklace is the standard mitigation and is a good example of a risk assessment changing the product rather than just adding a label.

5. Magnets

Magnetic clasps are popular and are a genuinely serious hazard if swallowed. Two magnets, or a magnet and a metal object, swallowed separately can attract across loops of bowel and cause perforation. This is not a theoretical risk, it is a well-documented category of paediatric emergency.

If you use magnetic clasps: assess whether the magnet can detach, keep them out of anything aimed at children, and warn explicitly. The toy standard uses a magnetic flux index threshold, which is a useful reference point even for non-toys.

6. Sharp points and edges

Wire ends, unfinished solder joints, broken links, faceted stone settings. Low severity, high likelihood in handmade work, and almost entirely controlled by your finishing process and final inspection. Worth a row precisely because the mitigation is a QC step you can describe.

7. Mechanical failure

Clasps opening, jump rings pulling apart, chains snapping. Mostly a loss-of-item problem rather than a safety one, but it becomes a safety issue for heavy pendants, for anything near the eyes, and for children.

8. The extras, if they apply

Resin and epoxy: skin sensitisation if not fully cured. Curing schedule and post-cure handling belong in your assessment.
Button batteries in light-up pieces: ingestion causes severe internal burns. Secured battery compartments requiring a tool are the expected control, and you are now also into battery labelling rules.
Natural materials: shell, bone, feathers and some woods bring their own allergen and origin questions.

The toy trap

Here is the distinction that most jewellery guidance gets wrong.

A toy under EU law is a product designed or clearly intended for use in play by children under 14. Jewellery a child wears as jewellery is not a toy. Play jewellery, dressing-up sets, jewellery-making kits and anything sold as part of pretend play is a toy, and toys are a different regime entirely: the Toy Safety Directive, CE marking, EN 71 testing, and a Declaration of Conformity.

So the question is not "is this for a child" but "is this for play". Get it wrong in the ambitious direction and you have an uncertified toy on the market. Get it wrong in the cautious direction and you have spent money on testing you did not need.

If your product is not a toy, EN 71 methods are still perfectly reasonable things to apply voluntarily, and saying so in your standards list is a legitimate way to show you used a recognised method where no specific standard exists.

A filled-in assessment

Product: sterling silver 45cm cable chain necklace with a lobster clasp, sold to adults.

Hazard	Who is affected	Likelihood	Severity	Controls applied	Residual risk
Nickel release causing allergic contact dermatitis	Adult wearers, higher for the nickel-sensitised	Low	Moderate	Nickel-free sterling sourced against supplier declaration SUP-2026-011; EN 1811 report on the 2026 alloy batch; clasp covered by EN 12472 wear simulation	Acceptable
Cadmium in alloy or plating	All wearers	Very low	High if present	Supplier certificate confirms below 0.01% by weight; certificate retained	Acceptable
Lead in accessible parts	All wearers	Very low	High if present	Supplier certificate confirms below 0.05% by weight	Acceptable
Choking on detached clasp spring (3mm)	Children under 3 handling the item	Low	High	Not marketed to children; "small parts, keep away from children under 3" on care card and listing	Acceptable
Strangulation from 45cm chain	Children	Low	High	Adult product only; no children's sizing in this line; warning on listing	Acceptable
Skin injury from broken chain or sharp link end	Wearers	Low	Low	Visual and tension check on every piece before dispatch, logged under QC-02	Acceptable

Six rows, one product, and every control in the right-hand column is something you can evidence: a certificate, a test report, a warning, or a logged inspection. That is the whole test of a good assessment. If a row's control cannot be evidenced, it is a wish, not a control.

The standards list that goes with it

EN 1811:2023, reference test method for release of nickel

EN 12472, method for simulating wear and corrosion on coated items

REACH Regulation (EC) 1907/2006 Annex XVII, entries 23, 27 and 63

Supplier material declarations SUP-2026-011, SUP-2026-014

Internal QC procedure QC-02

The warnings it produces

Small parts. Keep away from children under 3. Not suitable for children under 14. Remove before sleeping or swimming.

Notice those warnings are not decoration. Each one traces back to a specific row above. That traceability is what a market surveillance officer, or an EU Responsible Person doing their Article 16(2) checks, is looking for.

Doing this across a whole shop

One product is an afternoon. The problem is that a jewellery shop is rarely one product: it is silver, gold-fill and plated brass, studs and hoops and chains and pendants, and each combination shifts which rows apply and which supplier certificate is the relevant one. Then you change a clasp supplier and every affected assessment is out of date.

That is the part GPSRHub automates. You describe your products and materials once, and it produces the risk assessment, the technical file, the labelling sheet with these warnings on it, and a Declaration of Conformity for the products that need one.

The compliance checker is ten questions and about two minutes, and it will tell you which documents your specific products need before you spend a weekend on the wrong one. It is free.

Quick FAQ

Do I have to send my jewellery to a lab? Not necessarily. Supplier declarations and material certificates are accepted evidence for many small makers. Testing is stronger evidence and is worth it for high-volume lines or where you cannot get reliable supplier information.

What is the nickel limit? 0.2 µg/cm²/week for items inserted into piercings, 0.5 µg/cm²/week for other items in prolonged skin contact, measured under EN 1811.

Does "nickel free" on a supplier listing count as evidence? A marketing phrase on a product page is weak. A written declaration naming the alloy and the standard is what you want on file.

Is children's jewellery a toy? Only if it is intended for play. Jewellery worn as jewellery is not a toy, but play and dressing-up jewellery is, and that pulls in CE marking and EN 71.

How often should I redo the assessment? Whenever the product changes: new supplier, new alloy, new component, new target age group. Otherwise review it periodically so it does not silently go stale.