"Nickel-free" is one of the most common special requests on a safety-pin order, especially from babywear, medical and sensitive-skin brands. It is also one of the easiest requirements to write badly. The phrase is a commercial description, not a defined legal term in the European Union's nickel restriction, and it is not the same as a laboratory result for nickel release. This guide is for importers, brand buyers, garment factories and wholesalers who need to decide who actually needs a nickel-controlled pin, and then write a specification that a factory and a laboratory can follow.
It complements our comparison of brass, nickel-plated steel and stainless steel safety pins, which is about rust, wear and strength, and the sample evaluation checklist and certificates article. The question here is narrower: what "nickel-free" should mean on a purchase order, who typically needs that wording, and how to specify the European test methods used to measure nickel release.
This is general buyer guidance, not legal, customs, medical or laboratory advice, and it is not a statement that any named manufacturer holds ISO 9001 or any other certificate, or that any catalogue product has been tested to EN 1811 or EN 12472. Official sources below were fetched on 12 November 2026. Confirm the requirement for your market and your use with your compliance adviser, and agree the wording in the purchase order.
Quick answer
"Nickel-free" is not defined in REACH Annex XVII entry 27. If you only write that phrase, a supplier may read it as "no nickel plating", "no nickel in the alloy", or "passes a nickel-release test". Those are different promises. Write the meaning you need.
Where the EU restriction applies, the legal test is nickel release, not nickel content. Entry 27 of Annex XVII to Regulation (EC) No 1907/2006, in the consolidated text of 22 June 2026, limits release to 0.5 μg/cm2/week from parts of articles intended to come into direct and prolonged contact with the skin, and to less than 0.2 μg/cm2/week from post assemblies inserted into pierced parts of the body. The official text uses comma decimals (0,5 and 0,2).
The list of example articles in entry 27 is non-exhaustive, and it does not name safety pins. Whether a particular use is in scope is a case-by-case question for you and your adviser. Buyers who sell pins for skin-contact uses commonly specify the same limits and test methods anyway.
The test methods published for entry 27 are EN 1811:2023 (the reference nickel-release method) and EN 12472:2020 (accelerated wear and corrosion simulation for coated items), listed in Commission Communication C/2023/1604 of 20 December 2023. For a coated pin, the usual sequence is the EN 12472 simulation and then EN 1811. Confirm the sequence with the laboratory.
Typical buyers who need this wording are babywear and children's clothing brands, medical and healthcare buyers whose pins may sit against skin, sensitive-skin or nickel-allergy retail lines, and anyone placing skin-contact articles on the EU market.
A nickel-plated pin is not nickel-free. Stainless steel is not automatically nickel-free either. Common austenitic grades used for pins, including 304, contain nickel in the alloy, as the materials comparison already notes.
Ask for a lot-specific test report from a laboratory accredited to ISO/IEC 17025:2017, with the method on its scope. A catalogue name, a material certificate, or a report for a different size, finish or lot is not evidence for the goods you are buying.
Minimum order quantity is negotiable and depends on size, finish and packaging. Confirm the figure with the quotation, and discuss the specification through the enquiry form or the contact page.
What "nickel-free" does and does not mean
Buyers, catalogues and factories do not always use the same words in the same way. Before you treat a quotation as a match, separate three different ideas.
No nickel plating. This is the narrowest reading, and the one a factory may assume if you only write "nickel-free". It usually means the pin is not finished with a nickel electroplated layer. A solid brass pin with a non-nickel finish is a typical example in catalogues. That wording says nothing, on its own, about whether the alloy contains nickel, or about the rate at which nickel would be released in a laboratory test.
No nickel as an intentional alloying element. This is a composition claim. It is relevant if you want to avoid nickel in the metal itself, not only on the surface. It is a different statement from a release test, and it needs its own evidence, such as a composition analysis of the wire or the finished pin, with the method and the detection limit stated. Do not treat a plating description as proof of alloy composition.
Nickel release below a stated limit. This is the idea behind REACH Annex XVII entry 27. The restriction, where it applies, is written in terms of the rate of nickel release from the parts of the article that come into direct and prolonged contact with the skin, not in terms of a "nickel-free" label. A pin can contain nickel in the alloy and still have a low release rate if the surface does not release nickel above the limit. The reverse is also possible in principle: a marketing claim of "nickel-free" is not, by itself, a measured release result.
"Hypoallergenic" is in the same family of catalogue language. It is not a test method listed in Commission Communication C/2023/1604, and it is not a defined term in entry 27. If a brand needs a measurable requirement, write the test method, the edition and the limit, not a synonym.
Suvik's product catalogue currently lists brass pins described as nickel-free in size 00 (23 mm) and size 000 (19 mm). Treat a catalogue description as a starting point for a quotation, not as proof that a particular production lot meets a nickel-release limit. Ask for the material, the finish and the test evidence that match your specification.
Who typically needs a nickel-release specification
Not every safety-pin order needs this wording. A distributor buying pins for dry indoor garment tagging, where the pin is used briefly and is not sold as a skin-contact article, may have a different risk assessment from a babywear brand. The use, the market and the claim you will make to your own customer all matter. The groups below are the ones that most often need a written nickel requirement.
Babywear and children's clothing
Pins used on baby garments, nappies, bibs or accessories can sit against skin for long periods. That is a different exposure from a brief tagging use in a warehouse. If you sell into the EU, or you want the same discipline even where the legal analysis is still open, specify the skin-contact release limit and the CEN methods, and say that the intended use is babywear or children's clothing. Do not rely on a packing label that only says "nickel-free".
Medical, healthcare and first-aid uses
Safety pins are used to secure bandages and slings, and in hospital laundry and garment handling. Our medical uses page describes some of those applications. Skin-contact uses, such as fastening a dressing or a patient garment, are the ones that usually drive a nickel-release specification. Uses that are only about laundry durability or corrosion resistance are a different requirement, and they may point you towards a different material. The materials comparison is the place to work through rust, wear and strength. If you need both low nickel release and wet-service durability, write both requirements. Do not assume that one catalogue finish will meet them.
This article does not classify safety pins as medical devices, and it does not set a sterilisation or autoclave standard. If your product is a medical device, or must meet a healthcare procurement specification, take advice on those rules separately and put the agreed tests in the order.
Sensitive-skin and nickel-allergy retail
Brands that sell to customers who avoid nickel, or that market a sensitive-skin line, need a specification their quality team can check. A catalogue adjective will not help you if a customer later asks for evidence. Write the intended use, the test method and the limit, and keep the report with the lot.
Brands placing articles on the EU market
Entry 27, paragraph 2, says that articles which are the subject of paragraph 1 shall not be placed on the market unless they conform to those requirements. If your pins are intended to come into direct and prolonged contact with the skin in the EU, you need a compliance assessment, not only a marketing description. The next section sets out what the restriction actually says, and what it does not decide for you.
The EU legal test: REACH Annex XVII entry 27
The current consolidated text of Regulation (EC) No 1907/2006 (REACH) that we fetched on 12 November 2026 is dated 22 June 2026. Entry 27 of Annex XVII covers nickel (CAS No 7440-02-0, EC No 231-111-4) and its compounds. The wording of entry 27 in that consolidation is the same as in the earlier consolidation of 10 October 2024.
In summary, and without reproducing the whole annex, entry 27 says that nickel and its compounds shall not be used:
in post assemblies inserted into pierced ears and other pierced parts of the human body, unless the rate of nickel release is less than 0.2 μg/cm2/week (a migration limit);
in articles intended to come into direct and prolonged contact with the skin, such as earrings; necklaces, bracelets, chains, anklets and finger rings; wrist-watch cases, watch straps and tighteners; and rivet buttons, tighteners, rivets, zippers and metal marks when these are used in garments, if the rate of nickel release from the parts coming into direct and prolonged contact with the skin is greater than 0.5 μg/cm2/week;
in the skin-contact articles referred to above that have a non-nickel coating, unless the coating is sufficient to ensure that the release rate will not exceed 0.5 μg/cm2/week for a period of at least two years of normal use of the article.
Two drafting points matter for buyers.
First, the examples are introduced by "such as". They are illustrations, not a closed list. Safety pins are not named. Garment fasteners that are named include rivet buttons, tighteners, rivets, zippers and metal marks when used in garments. Whether a safety pin, in a particular intended use, is an article "intended to come into direct and prolonged contact with the skin" is a legal and factual question. This article does not answer it for your product. If the pin will be worn against the skin, or sold for that use, get advice and, in any event, consider specifying the same numerical limits and CEN methods so that you have measurable evidence.
Second, the legal quantity is a release rate, expressed in micrograms per square centimetre per week. A statement about nickel content, or the absence of a nickel-plated finish, is not the same measurement. Entry 27, paragraph 3, requires the standards adopted by the European Committee for Standardisation (CEN) to be used as the test methods for demonstrating conformity.
The 0.2 μg/cm2/week limit is written for post assemblies inserted into pierced parts of the body. Ordinary garment or first-aid safety pins are not described that way in the entry. Do not apply the tighter piercing limit to a garment pin unless your adviser tells you that your article is in that category.
This guide does not state a verified UK, US or other non-EU statutory limit. If you sell outside the EU, confirm the current rule in that market. Do not assume that an EU test report is accepted everywhere, and do not assume that a market without the same restriction makes a nickel specification unnecessary for your brand.
The test methods: EN 1811:2023 and EN 12472:2020
Commission Communication C/2023/1604 of 20 December 2023 publishes the titles and references of the European standards under entry 27. The communication we fetched on 12 November 2026 lists:
EN 1811:2023, "Reference test method for release of nickel from all post assemblies which are inserted into pierced parts of the human body and articles intended to come into direct and prolonged contact with the skin", superseding EN 1811:2011+A1:2015;
EN 12472:2020, "Method for the simulation of accelerated wear and corrosion for the detection of nickel release from coated items", superseding EN 12472:2005+A1:2009;
EN 16128:2015, a method for spectacle frames and sunglasses, which is not relevant to safety pins.
Name the edition in the order. A report to the superseded EN 1811:2011+A1:2015 is not the method listed in C/2023/1604. If a later Commission communication has replaced that list after the date of our fetch, use the methods in force when you test.
EN 1811:2023 is the reference method for measuring nickel release. EN 12472:2020 is not a substitute for that measurement. Its published title is a method for simulating accelerated wear and corrosion on coated items, after which nickel release is detected by the reference method. That pairing matches the structure of entry 27: a non-nickel coating must still keep release at or below 0.5 μg/cm2/week for at least two years of normal use. For an uncoated article, the reference release method listed is EN 1811:2023. Tell the laboratory whether the pin is coated, and agree whether EN 12472 is to be applied first.
The test is a laboratory method. It is not something an inspector can complete on a factory table during a pre-shipment inspection. The inspector can, if you write it into the inspection instructions, pull identified samples from the packed lot and send them to a laboratory.
Use a laboratory accredited to ISO/IEC 17025:2017, General requirements for the competence of testing and calibration laboratories, which is the current published edition on the ISO page fetched on 12 November 2026. Accreditation of the laboratory is not enough on its own: the nickel-release method, and the wear-simulation method if you need it, should be on the laboratory's scope for the type of article you are testing. The certificates article explains how to read a claim and check that it belongs to the organisation in front of you. Apply the same discipline to a test report.
Materials: do not confuse durability with nickel release
The live brass versus nickel-plated versus stainless comparison and the shorter brass versus steel guide are about which construction lasts in a given job. That is a different question from nickel release, even though the same three families keep appearing.
Nickel-plated steel is a steel core with a nickel finish. It is not a nickel-free product. It may be a sensible choice for dry indoor tagging, as the materials article explains, but it is the wrong starting point if your customer has asked for nickel-free pins.
Stainless steel is chosen for strength and wet-service durability. It is not automatically nickel-free. The materials article already states that common austenitic grades used for pins, including 304, contain nickel in the alloy, and that "stainless" is not the answer to a nickel-allergy specification. If you need stainless for durability and you also need a nickel-release result, specify the grade and the release test as separate lines.
Solid brass is often the catalogue choice when a buyer asks for nickel-free pins, because the pin is not nickel-plated and brass does not form iron rust. Composition still varies. "Brass" is not, by itself, a release result, and it is not a promise about every alloying element. If you need measured nickel release, say so, even when you have already chosen brass.
If your order also has to survive laundry, outdoor use or rough handling, write those performance needs next to the nickel requirement. A pin that meets a release limit but rusts, bends or loses spring has still failed the job. Approve a sample against the full specification, not against a single adjective.
What to write in the RFQ and the purchase order
Start from the RFQ template and add a nickel clause that a factory can quote against and a laboratory can test. The exact legal obligation depends on your market and use; the practical point is to remove ambiguity. Include, as applicable:
the intended use (for example babywear, children's clothing, medical or first-aid skin contact, sensitive-skin retail, or general garment tagging) and the destination market;
what you mean by "nickel-free", written as one or more of: no nickel plating; no nickel as an intentional alloying element, with a composition method if you need that claim; and/or conformity with the nickel-release limits in REACH Annex XVII entry 27 for the relevant category;
the material and finish in plain language (for example solid brass, unplated or with a named non-nickel finish; or a named stainless grade if you are buying stainless for durability and still require a release test);
the test methods and editions: EN 1811:2023, and EN 12472:2020 before EN 1811 if the article is coated, or the methods in any later Commission communication that is in force when you test;
the numerical limit that applies to your article, usually 0.5 μg/cm2/week for skin-contact articles under entry 27, unless your adviser specifies otherwise;
that testing must be done by a laboratory accredited to ISO/IEC 17025, with the method on its scope, on samples from the production lot being shipped, identified by order, size, finish and lot;
that a catalogue description, a mill certificate, or a test report for a different size, finish or lot is not acceptable evidence for this order;
what happens if the report is late or the lot fails, including that the goods should not ship until you have accepted the report or a written concession;
the usual points on size, packing, inspection and shipping terms.
Minimum order quantity is negotiable and depends on size, finish and packaging. Confirm the figure with the quotation. If you want the factory to comment on what it can actually supply and test, send the clause with your enquiry rather than adding it after production has started.
What a useful test report should contain
When the report arrives, read it as you would any other certificate: does it describe these pins, this lot, and the method you asked for? At a minimum, look for:
the laboratory's name, address and ISO/IEC 17025 accreditation, and a way to check that the nickel-release method (and EN 12472, if used) is on the scope;
the client's name, the order or lot reference, and a description of the sample (article type, size, material, finish, whether it is coated);
the methods and editions actually used, including whether EN 12472:2020 was applied before EN 1811:2023;
the result in μg/cm2/week, for the parts that were tested, with the date of test;
any measurement uncertainty the laboratory reports, stated as such, without treating uncertainty as a second, informal limit of your own invention;
identification of the samples, so that you can match them to the packed lot.
Reject, or query, a report that only says "nickel-free", "pass" or "hypoallergenic" without a method, edition and numerical result; a report dated well before production of your lot; or a report for a different product. Keep the accepted report with the order documents. It is useful evidence if you later have to raise a quality claim.
How to check samples and production lots
Agree the nickel wording before you approve a sample. The sample evaluation checklist is the place to compare dimensions, point, clasp, finish and packing against the reference sample. If nickel release is part of the specification, have the approved sample, or a retained piece from the same make, tested by the same method you will use on the production lot. A visual match is not a release test.
For the packed order, a third-party pre-shipment inspection can confirm quantity, workmanship, packing and that the goods match the approved sample. It cannot replace the laboratory test. If you want samples drawn from the packed lot, write that into the inspection instructions and leave time for the laboratory to report before the ship cut-off.
Do not treat a factory quality promise, or a system certificate, as a substitute. The quality-control buying guide and the certificates article cover those checks. They answer different questions from a nickel-release report on a defined lot.
Mistakes to avoid
Writing only "nickel-free" or "hypoallergenic". Those words are not a test method and are not defined in entry 27.
Treating stainless steel as nickel-free. Specify the grade for durability, and specify the release test if you need it.
Ordering nickel-plated pins for a nickel-controlled line. The finish itself is a nickel layer.
Taking a catalogue name as evidence. A product listed as nickel-free is an invitation to quote, not a lot-specific report.
Accepting an outdated method. Name EN 1811:2023, and EN 12472:2020 for coated items, or the later methods in force at the time of test.
Ignoring coatings. Entry 27 requires a non-nickel coating, where the restriction applies, to keep release at or below the skin-contact limit for at least two years of normal use. That is why EN 12472 exists.
Applying the piercing limit of 0.2 μg/cm2/week to an ordinary garment pin without advice that your article is a post assembly inserted into a pierced part of the body.
Shipping before you have accepted the report, or relying only on a check of goods after they have already left the factory.
Frequently asked questions
What does "nickel-free" mean for safety pins?
It is a commercial description, not a term defined in REACH Annex XVII entry 27. A supplier may take it to mean no nickel plating, no nickel in the alloy, or a pass against a nickel-release limit. Write which of those you need, and name the test method if you need a measured result.
Are safety pins covered by REACH Annex XVII entry 27?
Entry 27 applies to nickel and its compounds in post assemblies inserted into pierced parts of the body, and in articles intended to come into direct and prolonged contact with the skin. The examples in the entry are non-exhaustive and do not name safety pins. Whether a particular safety-pin use is in scope depends on the intended use and should be confirmed with your compliance adviser. Buyers supplying pins for babywear, medical skin contact or other prolonged skin-contact uses commonly specify the entry 27 limits and the CEN test methods in any case.
Is stainless steel nickel-free?
No. Common austenitic grades used for pins, including 304, contain nickel in the alloy. Stainless steel can still be the right choice for rust and strength, and it may or may not meet a nickel-release limit in a laboratory test. Do not treat the word "stainless" as a nickel-free specification.
What test should I ask a supplier to provide?
For an EU skin-contact specification, ask for nickel release tested to EN 1811:2023, and, if the pin is coated, for the EN 12472:2020 wear and corrosion simulation first, unless a later Commission communication has superseded those methods. State the limit (usually 0.5 μg/cm2/week for skin-contact articles under entry 27) and require a report from an ISO/IEC 17025-accredited laboratory, on samples from the lot you are buying.
Can a pre-shipment inspector carry out the nickel-release test at the factory?
No. EN 1811 and EN 12472 are laboratory methods. An inspector can pull identified samples from the packed lot, if you have written that into the inspection plan, and those samples can be sent to a laboratory. Leave time for the report before shipment.
If a product is already listed as nickel-free, do I still need a test report?
Yes, if you need evidence for a release limit or a composition claim. A catalogue listing describes a product line. It is not a report for your size, finish and production lot.
Specify the requirement before you approve the sample
If you buy safety pins for babywear, medical skin contact, sensitive-skin lines or the EU skin-contact market, do not leave "nickel-free" as a one-line remark in a chat. Write the intended use, the meaning of the requirement, the methods, the limit and the evidence you will accept, then approve a sample and a lot report against that wording.
Minimum order quantity is negotiable. To discuss a specification or a quotation, use the enquiry form or the contact page.
Sources
Regulation (EC) No 1907/2006 (REACH), consolidated text of 22 June 2026, Annex XVII entry 27 (fetched 12 November 2026; entry 27 wording matches the 10 October 2024 consolidation)
Commission Communication C/2023/1604 of 20 December 2023, standards under REACH Annex XVII entry 27 (fetched 12 November 2026)
ISO/IEC 17025:2017, General requirements for the competence of testing and calibration laboratories (fetched 12 November 2026)
European Commission, REACH restrictions (fetched 12 November 2026)
Live Suvik Overseas pages linked in the body, each checked HTTP 200 on 12 November 2026 (see plan-2026-11/day11/linkcheck-2026-11-12.txt)