Whether REACH Entry 51 covers your charms depends on which kind of enamel is on them — and the report that proves it is a GC-MS phthalate analysis of the enamel itself, not your silver assay. Entry 51 of REACH Annex XVII caps four phthalates (DEHP, DBP, BBP and DIBP) at below 0.1% by weight of the plasticised material. Properly fired vitreous enamel is inorganic glass fused onto the metal: it contains no plasticiser, so there is nothing for Entry 51 to restrict. Cold enamel, resin and epoxy coatings are polymers that can carry phthalate plasticisers, so they are in scope — and an adult charm worn all day easily counts as prolonged skin contact. Demand IEC 62321-8 GC-MS testing with the enamel sampled separately as a homogeneous material, a report citing Entry 51 and the 0.1% w/w basis, and put that clause into your PO.
Entry 51 of Annex XVII to Regulation (EC) No 1907/2006 (REACH) restricts four phthalates: bis(2-ethylhexyl) phthalate (DEHP, CAS 117-81-7), dibutyl phthalate (DBP, CAS 84-74-2), benzyl butyl phthalate (BBP, CAS 85-68-7) and diisobutyl phthalate (DIBP, CAS 84-69-5). As amended by Commission Regulation (EU) 2018/2005 — which added DIBP to the restricted list — the limit is below 0.1% by weight of the plasticised material, individually or in any combination, applying from 7 July 2020.
Two details decide how the entry reads for jewelry. First, the denominator: the limit is calculated on the plasticised material — the coating or soft component itself — not on the whole article. Second, the scope: the restriction reaches articles containing plasticised material that come into prolonged contact with human skin, which the amendment defines as continuous contact of more than 10 minutes or intermittent contact over a period of 30 minutes per day.
Note what is not in that list: nickel, lead and cadmium sit under different entries and different reports. Entry 51 is to phthalates what entry 27 is to nickel release — a separate line item that needs its own evidence.
Real enamel — the kind fired in a kiln — is glass. GIA describes enameling as “fusing glass in some form onto a metal substrate,” with the enamel in ground, powdered form melted in a furnace or with a hand-held torch. The result is an inorganic silicate glass, typically kiln-fired in the 750–850 °C range onto the silver. Plasticisers are additives that soften polymers — PVC, rubbers, resins. Fused glass contains no polymer, so it cannot carry a phthalate plasticiser, and it is not “plasticised material.”
The correct compliance statement for fired enamel is therefore “Entry 51 does not apply,” not “tested and passed.” No phthalate method can prove a pass on glass, because there is nothing for the method to extract and measure. What you should ask for instead is a scope judgment: a short material-identification statement confirming the decoration is vitreous inorganic glass — an FTIR scan showing no organic polymer spectrum, for example — plus a supplier declaration that no plasticised material is used in that decoration.
This boundary is where many summaries go wrong: some assume every enamel coating is automatically restricted, others wave the topic away entirely. The boundary is not the word “enamel” on your order sheet; it is how the color layer was physically made.
“Cold enamel” is the trade name for polymer resin — usually a two-part epoxy — cured without a kiln. It looks like enamel and is sold as enamel, but chemically it is a coating polymer, and polymers are exactly the materials Entry 51 governs. If the formulation uses a plasticiser, the coating is plasticised material and the restriction applies.
Adult marketing does not exempt it. Paragraph 3 of Entry 51 is not keyed to how an article is marketed: since 7 July 2020 it has barred placing on the market any article containing DEHP, DBP, BBP or DIBP at or above 0.1% w/w of the plasticised material, and a charm sold to an adult collector is just as much an “article” as anything else on the shelf. The charm also easily clears the exposure test: it sits against skin all day, which is continuous contact far beyond the 10-minute threshold in the definition. One boundary is worth knowing precisely, because summaries blur it: the “can be placed in the mouth by children” category belongs to Entry 52, which restricts the other three phthalates — DINP, DIDP and DNOP — only in toys or childcare articles that can be placed in the mouth by children, not in general articles; it does not touch Entry 51, which since 7 July 2020 covers these four phthalates in all articles placed on the market. So for any cold-enamel charm — adult or not — assume Entry 51 applies unless the report says otherwise.
While you are at it, look beyond the decoration. Silicone stoppers, rubber backs, PU cords, adhesive pads and plastic beads on the same article are all plasticised-material candidates, and the same 0.1% w/w judgment applies to each of them as its own material.
The method to name is IEC 62321-8:2017 — “Determination of certain substances in electrotechnical products – Part 8: Phthalates in polymers by gas chromatography-mass spectrometry (GC-MS), gas chromatography-mass spectrometry using a pyrolyzer/thermal desorption accessory (Py-TD-GC-MS).” It covers the seven phthalates most regimes care about — DIBP, DBP, BBP, DEHP, DNOP, DINP and DIDP — and the four REACH Entry 51 phthalates lead that list. GC-MS is the quantitative reference technique, while the pyrolyzer/thermal-desorption variant lets a lab screen a coating quickly.
Notice the phrase “in polymers” in the title. The standard is written for polymer materials — which is precisely what cold enamel is. That is a second way to see the applicability boundary: there is a recognized phthalate method aimed at resin coatings because resins are the risk, and no phthalate method aimed at kiln-fired glass because glass is not.
Ask the report to state which technique was used — solvent-extraction GC-MS or Py-TD-GC-MS — and whether the result is a quantitative determination or a screening result, because the two are not interchangeable once a shipment is in dispute.
The most common reason a real non-compliance hides behind a passing report is sampling. If the lab grinds whole charms, the silver — the overwhelming share of the weight — dilutes the coating by exactly its share of the piece. A resin layer carrying a phthalate level far above 0.1% of its own weight can read as a harmless fraction of a whole-charm sample, because the denominator in the calculation becomes the metal rather than the plasticised material.
The correct instruction follows the homogeneous-material logic used across REACH and RoHS enforcement: the enamel layer is a distinct homogeneous material, so it must be separated and tested as its own sample. In practice, the lab removes the coating — mechanically or with a suitable solvent — from several pieces of the same production lot, combines the removed material if the mass is small, and reports results for the coating material itself, with the sample description saying so.
Put that sentence into the test order: “Enamel coating to be tested separately as a homogeneous material per IEC 62321-8; do not test whole-charm composites.” A lab that cannot separate a coating from a metal substrate will also struggle to defend the result later.
A phthalate report is PO-usable when you can read it against Entry 51 line by line. Before accepting one, check that it states all of the following:
| Report line | What to demand | Why it matters |
|---|---|---|
| Method | IEC 62321-8 (GC-MS), technique stated: solvent extraction or Py-TD-GC-MS | Ties the numbers to a recognized phthalate method for polymers |
| Substances | DEHP, DBP, BBP, DIBP named individually with CAS numbers | The four Entry 51 phthalates, not a generic “phthalates: negative” |
| Образец | Described as the separated enamel layer (homogeneous material), with photos | Closes the whole-charm dilution trap |
| Result basis | Each phthalate judged against 0.1% w/w of the plasticised material, with detection limits stated | The legal denominator; a pass means nothing without it |
| Criterion | Explicit citation of REACH Annex XVII Entry 51 | Makes the report self-standing evidence for EU market checks |
| Traceability | Report number, test date, lab identity, linked to your PO and approved color | Connects the result to the goods you actually receive |
For a kiln-fired vitreous enamel, swap the phthalate panel for the scope judgment described above: a material-identification statement confirming the coating is inorganic glass, plus a declaration that no plasticised material is used in the decoration, and an Entry 51 panel for any polymer parts on the same article.
One honesty check helps here: look at what the factory already publishes. Our certifications page shows a third-party panel — silver assay at 976.8 per mille, nickel release not detected to EN 1811:2023 against REACH entry 27, lead reported at 17.1 mg/kg against a 1,000 mg/kg limit — and that published report contains no phthalate line at all. A strong heavy-metal panel is not a phthalate report. The enamel needs its own line item, and asking for it is normal, not adversarial. The same accountability logic applies when a subcontractor fails a panel, as our EN 1811 plating story shows.
Use two clauses, keyed to the decoration type:
Fired vitreous enamel: “Decoration is kiln-fired vitreous enamel (inorganic glass). Supplier declares the decoration contains no plasticised material and provides a lab material-identification statement confirming vitreous glass. Any polymer component on the article (silicone, rubber, resin beads, adhesives) complies with REACH Annex XVII Entry 51: DEHP, DBP, BBP and DIBP each below 0.1% w/w of the plasticised material, evidenced by GC-MS testing per IEC 62321-8.”
Cold enamel / resin coating: “Decoration is cold enamel (polymer resin). Supplier provides a third-party report per IEC 62321-8 (GC-MS) with the enamel sampled and tested separately as a homogeneous material; DEHP, DBP, BBP and DIBP each below 0.1% w/w of the plasticised material; the report cites REACH Annex XVII Entry 51, states its detection limits, and carries a report number traceable to this PO and the approved color.”
Retest triggers are material events, not calendar dates: a new resin supplier, a reformulated color, a new decoration house, or a new OEM project where the enamel source is unknown. Bake the clause into the custom OEM/ODM specification stage so the sampling instruction reaches the lab before the first sample does.
Just the plasticised material. The limit is calculated on the weight of the coating or soft component itself, which is exactly why whole-charm results cannot decide this question.
No. CPSIA is the US children’s-product regime with its own scope and basis. Useful as a supplier signal, but an EU-facing PO needs a report citing REACH Annex XVII Entry 51 and the 0.1% w/w of plasticised material basis, on a sample described as the separated coating.
Not for the enamel. Ask for the coating to be tested separately as a homogeneous material; a whole-charm result dilutes the coating by the metal’s share of the total weight.
No. Sterling silver is metal, not plasticised material. The phthalate risk sits in polymer coatings and polymer parts; the metal’s chemical story is the heavy-metal panel — nickel release, lead, cadmium — which is published and read separately.
On material events: a new resin supplier, a reformulated color, a new decoration subcontractor, or a new project with an unknown enamel source. When nothing changes, tie a periodic retest to your batch-approval routine so it happens with the shipment, not around it.
Fired vitreous enamel: Entry 51 does not apply — prove it with a material-identification statement, not a phthalate panel. Cold enamel or resin: Entry 51 applies — prove it with an IEC 62321-8 GC-MS report on the separated coating, citing Entry 51 and the 0.1% w/w basis. Put the right clause in the PO, and the report you receive will actually mean something.
