GPSR for Jewellery and Accessories

Jewellery looks like the safest category in e-commerce: a small product, low price, no electronics. And yet it's cheap jewellery from Asia that regularly shows up in the EU Safety Gate system - most often for exceeding cadmium, lead or nickel limits. If you sell earrings, bracelets, chains or hair accessories imported from China on Allegro, Regulation (EU) 2023/988 (GPSR), applicable since 13 December 2024, applies to you in full: from risk assessment through responsible person details to labelling. This article shows what to watch for in this specific category. If you're new to the topic, start with What is GPSR? A Guide for Sellers.

Why jewellery is not a "low-risk category" at all

Jewellery stays in constant contact with skin, gets mouthed by children, and is made of cheap metal alloys of unknown composition. That's enough for market surveillance authorities to inspect it regularly. Three main problems:

• Heavy metals in alloys - cadmium and lead in cheap alloys are the most common reason jewellery gets reported to Safety Gate. The limits come from REACH.
• Nickel - responsible for contact allergies. Nickel release limits apply to parts in prolonged skin contact (earrings, clasps).
• Small parts and magnets - beads, charms and magnetic clasps a child can swallow. Swallowed magnets are among the more serious hazards recorded for such products.

GPSR and REACH: two rule sets, one product

For jewellery, GPSR and REACH work together. REACH restricts specific substances (cadmium, lead, nickel), while GPSR requires you to assess the product's safety as a whole and document it. In practice, your risk assessment must answer: how do I know the alloy in this chain is within the limits? The answer is a chemical composition test report - from the manufacturer or a laboratory. How to tell a credible report from a decorative PDF is covered in Chinese Supplier Certificates: What's Valid Under GPSR.

GPSR requires the safety assessment to take into account, among other things, the product's chemical properties and consumer groups at particular risk, including children. For jewellery, the question is not just "does the clasp work" but above all "what is in the alloy and who will wear it".

Children's jewellery: a league of its own

Beaded bracelets, earrings for girls, hair ornaments - if the product targets children, the bar goes up:

• stricter chemical limits,
• choking hazards from small parts, which must survive a pull test without detaching,
• a thin line between children's jewellery and a toy: a product with play features may be classed as a toy, triggering CE marking and the Toy Safety Directive - see GPSR for Toys: Additional Requirements.

The documents and markings you need

Obligation	How to meet it for jewellery
Risk assessment and technical documentation	Product description, materials, composition test results, hazard analysis (chemistry, small parts, magnets)
Manufacturer details	Name, address and contact of the Chinese manufacturer, or yours if you sell under your own brand
EU responsible person	Usually you as the importer; details in the listing and on the packaging
Traceability	Model or batch number on the unit packaging (for a small product: a label on the pouch or tag)
Warnings	In Polish, e.g. "not suitable for children under 3" where small parts are present
Online listing data	Allegro GPSR fields: manufacturer, responsible person, warnings, labelling photos

A small product doesn't exempt you from labelling - if the data doesn't fit on the item, you put it on the packaging or an accompanying document. Practical solutions are described in Responsible Person Details: Label and Listing Rules.

How to talk to your jewellery supplier

Before ordering a larger batch, ask the supplier for:

• a cadmium and lead content test report for the specific alloy,
• a nickel release report for skin-contact parts,
• a declaration of compliance with REACH restrictions,
• manufacturer details for labelling,
• the production batch information, so you can link it to the reports.

If the supplier can't provide any of these, that's a warning sign - such batches most often end up as Safety Gate reports. What happens after such a report is covered in Safety Gate, Reporting and Product Withdrawal.

Common mistakes made by jewellery sellers

• selling "silver" jewellery without knowing the actual alloy,
• no chemical testing at all for cheap alloys,
• mixing batches from different suppliers under one listing with no traceability,
• no warnings on products with small parts or magnets,
• treating children's jewellery the same as adult jewellery,
• missing responsible person details in the listing.

Checklist for a jewellery seller

• establish the alloy composition and obtain test reports for cadmium, lead and nickel,
• do a risk assessment covering children and allergy sufferers,
• label the packaging with manufacturer, responsible person and batch number,
• add Polish warnings where needed,
• complete the GPSR fields in every listing,
• archive documents for 10 years, linked to delivery batches.

Frequently asked questions

Does jewellery need CE marking?

No. Jewellery is not subject to CE-marked legislation unless it is classed as a toy. It is, however, subject to GPSR and the chemical restrictions in REACH.

Do I really have to test cheap jewellery from China?

GPSR requires you to be able to demonstrate product safety. For cheap metal alloys, the only credible proof of compliance with cadmium, lead and nickel limits is a test report - from the manufacturer or a laboratory.

Where do I put the data if the product is tiny?

If the data doesn't fit on the item, GPSR allows placing it on the packaging or in a document accompanying the product. In practice, a label on a zip pouch or a hang tag works well.

Does handmade jewellery made in Poland also fall under GPSR?

Yes. If you sell handmade jewellery, you are its manufacturer: you're responsible for the risk assessment, safe materials, and labelling with your details. You don't need a separate responsible person, because the product is made in the EU.