The European Federation of Associations of Locks & Builders Hardware Manufacturers

Restriction of nickel

ANNEX XVII to REACH deals with ‘Restrictions on the manufacture, placing on the market and use of certain dangerous substances, mixtures and articles’

Entry 27 to ANNEX XVII covers the restrictions concerning nickel and nickel containing articles.

Entry 27 in its present version does not include any nickel containing building hardware products or components of building hardware products. 

(see document REACH, Annex XVII, Entry 27).

Success story ‘Nickel Guideline’

In Q1/2017 the European Chemicals Agency (ECHA) published the ‘Draft guideline on articles intended to come into direct and prolonged contact with the skin in relation to restriction entry 27 of Annex XVII to REACH on: Nickel and nickel compounds’. This draft guideline listed keys, key rings and key fobs under ‘Articles that have been reported to cause nickel allergy and examples of similar types of articles’. For ARGE the inclusion of keys in the respective table of the draft was extremely alarming, as, if the guideline had become an official document of ECHA, the use of nickel in keys could have been restricted or even prohibited. Strongly supported by ARGE’s German member, FVSB, and side by side with the CLEPA, The European Association of Automotive Suppliers, ARGE lobbied at ECHA, explaining why keys, key rings and key fobs should be eliminated from this list.

As a result of powerful individual lobbying in relation to several product lines and due to strong opposition from the Nickel Institute in Brussel, which ARGE has been working closely with, the European Commission and ECHA decided to discontinue the preparation of the guideline. 

The European Commission will now consider an alternative route within the REACH regulation, which is also aimed at the further restriction of the use of nickel. With this in mind, ARGE will remain closely involved in this matter, especially as some member states of the European Union are dissatisfied with the discontinuation of the work on the nickel guideline.