The material

Children’s Jewellery: Why the Metal Matters More Than the Design

US law caps lead tighter in a coating than in the metal underneath it. So the simplest way to pass a children's jewellery test is to not have a coating at all.

Toshit Dangi, Founder of Argentia
Written by Toshit Dangi
Argentia, Argentium Registered User AS2475 · 12 min read

The short answer.

  • In the US, children’s jewellery means age 12 and under. At 13 a different standard applies.
  • Lead is capped at 100 ppm in the metal but 90 ppm in a coating. The law is stricter about what is on top.
  • Coatings also have to be tested for antimony, arsenic, barium, chromium, mercury and selenium.
  • Anything pierced through skin must pass nickel release limits. Plating is usually laid over a nickel underlayer.
  • A piece with no coating removes all of that. Not by passing the test, by not having the part that fails it.

Most conversations about children’s jewellery are about design. Size, safety catches, whether the clasp is easy enough for small hands.

The regulations are about none of that. They are almost entirely about what the piece is made of, and specifically about what has been put on the surface of it.

Where the legal line sits

In the United States, a children’s product means one designed or intended primarily for children 12 years of age or younger. That is the CPSIA definition, and it is the line everything else hangs off.

The jewellery standards follow it exactly. ASTM F2923 is written for children’s jewellery, meaning up to 12. ASTM F2999 is the adult standard, and it applies to consumers older than 12.

12
Age limit for a
children’s product
100ppm
Lead cap
in the metal
90ppm
Lead cap
in a coating
75ppm
Cadmium cap
in any component

So a pair of earrings made for a 12 year old carries the full weight of children’s product law: third party testing, a Children’s Product Certificate, and a permanent tracking label on the product and on the packaging. The identical pair sold for a 13 year old does not.

If you sell to that age group, or near it, assume you are in the children’s category and specify accordingly.

Three pairs of small silver stud earrings with screw backs, photographed on white
Unplated, so there is no coating to test. US law caps lead at 100 ppm in the metal but 90 ppm in a surface coating, and coatings carry six further element tests.

The rule that decides everything

Read the two lead limits again.

WhereLead limit
The metal itself100 parts per million
Surface coating or paint90 parts per million

The law is stricter about the coating than about the metal underneath it. That is not an accident. Coatings sit on the outside, they wear, and they end up on skin and on hands.

It goes further. Any paint or coating on children’s jewellery also has to be tested for antimony, arsenic, barium, chromium, mercury and selenium. None of those tests apply to a surface that was never coated.

The practical consequence.

Every layer you add to a child’s piece adds a set of tests, a set of limits, and a set of ways to fail.

An unplated piece does not pass the coating tests. It does not have the part being tested.

This is the opposite of how the trade normally thinks about plating. In adult jewellery, plating is the fix. In children’s jewellery, plating is the thing the regulation is most worried about.

The nickel question, and why it is permanent

ASTM F2923 requires that any jewellery intended to be pierced through the skin, such as earring posts, or worn against the skin for a prolonged period, must pass maximum metal release specifications for nickel.

That is the right rule, and the reason it exists is worth understanding properly.

Nickel allergy is the most common contact allergy in the world. In Europe it affects roughly 8 to 19 per cent of adults, and it is four to ten times more common in women than men. Once a person is sensitised, it is lifelong. There is no cure and no desensitising.

And the most common route to becoming sensitised is pierced ears. Which means most adults who cannot wear jewellery today were sensitised as children.

This is the part that makes children’s jewellery different from every other category.

A freshly pierced ear is an open wound with metal sitting in it for weeks. If that metal releases nickel, the child may be sensitised for the rest of their life, and every piece of jewellery they ever buy will have to work around it.

Getting this wrong once has consequences measured in decades.

Now the detail most people miss. Sterling silver contains no nickel. The problem is not the alloy, it is what is plated onto it. Rhodium plating is very commonly applied over a nickel underlayer, because nickel is what makes the plating adhere. So a piece that is nickel free on paper becomes a nickel problem the moment the plating wears through.

On a child’s jewellery, worn constantly, slept in, worn through PE and swimming, that happens faster than anyone expects.

Why precious metal is treated differently

CPSIA carves out an exemption worth knowing. Precious metals, meaning karat gold, sterling silver and the platinum group metals, and gemstones that have not been treated in a way that could add lead, are exempt from third party testing.

The reasoning is straightforward. These materials are inherently unlikely to contain the substances the rules are aimed at.

But read the scope carefully. The exemption covers the metal. It does not cover a coating applied to the metal, or a base metal component, or a treated stone. Add any of those and the exemption stops doing the work for you.

So the simplest children’s jewellery specification is a precious metal with nothing on it and nothing treated in it.

Two silver bracelets side by side, one darkened and patchy, one bright and even
What wear actually looks like. Plating goes unevenly at the contact points, so the piece ends up part bright and part grey, which reads worse than plain silver would have.

The state laws that go further

Federal law is the floor, not the ceiling.

StateWhat is different
CaliforniaCadmium content limit, plus Proposition 65 warning obligations covering lead and cadmium
MinnesotaOwn cadmium rules for children’s jewellery
IllinoisOwn limits, not pre-empted by CPSIA
Connecticut and MarylandHard cadmium content limits
New YorkLabelling duty rather than a content limit

Which is why a supplier saying "we are CPSIA compliant" has told you very little. The useful questions are which states, which standard, and what the test report actually covers.

What Argentium changes

Argentium replaces the copper in sterling with germanium, which forms a clear self repairing layer at the surface instead of a tarnish film. The reason that matters here is not the tarnish. It is that the piece does not need plating to stay white.

Follow that through against the rules above.

RequirementPlated sterlingArgentium 960, unplated
Lead in coating, 90 ppmAppliesNo coating
Soluble metals in coatingSix elements to testNo coating
Nickel releaseNickel commonly in the underlayerNo nickel in the alloy
What happens as it wearsUnderlayer becomes exposedNothing to wear through
Silver content92.5%96%
Green marks on skinCopper in the alloyNo copper

The argument is not that Argentium passes the tests better. It is that most of the tests are about a layer it does not have.

There is a second benefit that shows up later. A child’s first proper jewellery is often kept. Plated pieces look worn within a few years and cannot be replated cheaply. An unplated piece at 96 per cent silver comes back with a cloth, twenty years later.

Child's hand on a school desk wearing a thin silver chain bracelet
Worn daily, not occasionally. A piece that goes to school every day wears through a coating far faster than one kept for functions.

What to specify, whether you are a brand or a parent

The same list works for both, because it is all checkable.

  1. Unplated. Ask directly. If the answer is yes it is plated, ask what the underlayer is.
  2. Nickel free by composition, not nickel free because of a coating.
  3. Stamped. Argentium carries the Winged Unicorn mark and the grade, so the metal can be verified rather than trusted.
  4. Test report for the states you sell into, not just "CPSIA compliant".
  5. Tracking label on product and packaging, if the buyer is 12 or under.
  6. Untreated stones, or the precious metal exemption stops applying.
  7. Secure fittings. Screw backs on earrings for younger children, and a clasp a child can actually work.

What this article does not cover

Babies and toddlers are a different question and this is not about them. The American Academy of Pediatrics does not recommend that infants wear jewellery of any kind, and the FDA has warned against teething necklaces and bracelets following reports of choking and one strangulation death. No metal, however good, changes a choking or strangulation risk. We do not make jewellery for infants.

Argentium is not tarnish proof. It is highly tarnish resistant, up to seven times more than sterling. It is silver, and silver eventually shows something.

This is not legal advice. Limits change, states differ, and the test report is what counts. Verify against current CPSC guidance and your own lab before you sell.

The short version

Children’s jewellery regulation is mostly about surfaces. Lead is capped tighter in a coating than in the metal. Coatings carry six extra element tests. Nickel release is governed for anything in a piercing, and nickel is usually in the plating underlayer rather than the metal.

So the simplest way to make a child’s piece that passes is to build it from a precious metal that does not need a coating. That is what Argentium 960 is: 96 per cent fine silver, no nickel, no plating, stamped so it can be verified.

We make in Argentium 960 only, as an Argentium Silver Trademark Registered User, registration AS2475. If you are putting together a children’s line, send us the designs and the states you sell into and we will tell you what the specification needs to say.

Unplated, nickel free, stamped

India’s first house of Argentium silver

Argentium 960 only, Winged Unicorn stamped, Registered User AS2475. Wholesale, white label and private label. Minimum order 300 grams.

Ask about a children’s line

or email toshit@argentia.in