If your Consuming Item Direct and Prolonged Skin Contact then must be ensure it is “azo”, “Nickel” & “Chrome VI” OR Other restricted substances Free.

The generally accepted industry standard for the term direct and prolonged contact with human skin or oral cavity is items in contact with the skin or oral cavity for more than 30 minutes per day, every day. However ‘every day’ is an ambiguous measurement so the following guidelines should be used for products:

Direct and prolonged skin contact = when an item is in continuous contact with the same area of skin or oral cavity for more than 30 minutes at a time (regardless of the number of days worn, even if the item is only worn occasionally).

Examples of ‘direct and prolonged’ contact’:
 watch straps, belt buckles, insides of belts, trims on the inside of garments, metal components on shoulder straps of bags, fabric on clutch bags.

Examples of NOT ‘direct and prolonged contact’:
 Trims on the front or back of bags that might be ‘brushed’ by an arm when the item is in use but are not in constant contact with the same bit of skin.
 Components on arms of sunglasses that may be touched when the glasses are taken on and off, but are NOT in contact with the skin when worn.
 Metal components on clutch bags (not likely to be in continuous contact with the same area of skin for long periods of time).

Legislation that relates to ‘direct and prolonged skin contact’

1) Azo Directive
REACH Annex XVII (formerly 2002/61/EC, 2003/3/EC (19th and 12th amendments of 76/769/EEC))

Included in the Directive
Components in direct and prolonged contact on the following items:
 Clothing, bedding, towels, hairpieces, wigs, hats, nappies and other sanitary items, sleeping bags.
 Footwear, gloves, wristwatch straps, handbags, purses/wallets, briefcases, chair covers, purses worn round the neck.
 Textile or leather toys and toys which include textile or leather garments.
 Yarn and fabrics intended for use by the final consumer.
Included in safty Policy on Azo dyes:
All textile and leather components on the following;
- any products in direct and prolonged contact with the skin
- covered belt buckles
- inside of belts
- straps and handles of bags
- clutch bags
- purses and wallets
2) Nickel Directive
REACH Annex XVII entry 27 (formerly 94/27/EEC (12th Amendment of 76/769/EEC) and 2004/96/EC)

Included in the Directive:
Components in direct and prolonged skin contact on the following items;
 Post assemblies inserted into pierced ears and other pierced parts of the human body
 Articles intended to come into direct and prolonged contact with the skin
 Earrings
 Necklaces, bracelets and chains, anklets, finger rings
 Wrist-watch cases [casings, not packaging cases], watch straps and tighteners
 Rivet buttons, tighteners, rivets, zippers and metal marks, when these are used in garments

Included in safty Policy on Nickel:
Components in direct and prolonged skin contact on the following items:
 Spectacle frames and sunglasses, fashion and prescription (metal framed product to be tested, hinges NOT to be tested)
 Chain cufflinks (chain part only)
 Hair accessories
 Shoe trims

Excluded from safty Policy on Nickel:
 Cutlery
 Pens
 Bar cufflinks
Non Legislative restricted substances that relate to ‘direct and prolonged skin contact’

1) Chrome VI
Chrome VI restricted to 3ppm (0.003%) in all leather components in direct and prolonged contact with the skin

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