FAQs

Dermatitis FAQ’s:

  • Dermatitis means an inflammation of the skin. Dermatitis can have many causes and occurs in many forms. It usually involves an itchy rash on swollen, reddened skin.

  • The term ‘Contact Dermatitis’ is used when the skin inflammation is caused by contact with something in its immediate environment. There are two types of Contact Dermatitis - Allergic Contact Dermatitis (ACD) and Irritant Contact Dermatitis (ICD).

  • When a specific substance on repeated and prolonged contact sensitises the immune system and trigger an allergic response, this causes a local inflammation which is termed as Allergic Contact Dermatitis (ACD) commonly known as ‘Skin Allergy’, and the substance is then called an allergen. The immune system is a host defence system comprising many biological structures, organs and processes of the body that provide resistance to infection and toxins and protects us against disease. Organs include the thymus, bone marrow, and lymph nodes.

  • If an inflammation of the skin is caused by its exposure to metal allergens (e.g., Nickel, Cobalt, etc.), then it is termed as Metal Induced Allergic Contact Dermatitis’ (MACD). If you avoid the offending metal allergens, the skin inflammation should go away.

  • Certain substances such as detergents, soaps, cleaners, chemicals even hard water with chlorine, etc., have the ability to abrade, irritate or traumatise the skin when they are in its direct contact. These substances can strip off skins natural oils and remove its surface protective layer when they are in contact with skin long enough. This can lead to skin damage which causes irritation /inflammation, and it is called Irritant Contact Dermatitis (ICD).

    A person can develop Irritant Contact Dermatitis quickly from a single exposure to a strong irritant. Weaker irritants will require repeated exposure. It most commonly affects the hands. Irritant Contact Dermatitis often considered the first step toward Allergic Contact Dermatitis. No clinical signs and symptoms can unambiguously discriminate between ACD and ICD and differentiation between two is not always straightforward.

Skin Allergy FAQ’s:

  • There are eight million people living with skin disease in the UK. Some are manageable; others are severe enough to be fatal. (British Skin Foundation, 2016)

    Approximately 20% of the European population have dermatitis. 15% of people in the EU have Metal Induced Allergic Contact Dermatitis’ (MACD) commonly known as ‘Skin Allergy’ due to metal contact.

    Nickel, Cobalt and Chromium are the top three metal allergens. These metals occur in many types of products- for example, jewellery, watches, eyewear’s, textile, leather, hides, furs, studs in jeans and other clothes, bra straps, etc. and they are difficult to avoid.

    Besides Nickel, Cobalt and Chromium, there are several other transition metals that are now of growing concern amongst dermatologists for their capability to act as allergens under certain circumstances, they include Au, Hg, Be, Pd, Pt, Mn, Al, Cu, Fe, Mo, Sn, Ti, Zn, etc.

    MACD has a non-reversible effect; this means once a person is allergic, they are likely to continue to be allergic throughout their life, and some individuals react to very low concentrations of metal allergens. Therefore, once a person is sensitised to an allergen, they must avoid exposure to that allergen for the rest of their life to prevent allergic reactions. Furthermore, data show that there is no difference in the prevalence of contact allergy between children and adults. This means that a person can get sensitised at a very young age and can be affected during their entire life. Another factor contributing to the severity of the problem is the fact that people cannot easily avoid exposure to jewellery, watches, clothes, and footwear etc., they must in practice be worn on a daily basis throughout a person’s lifetime.

    Although skin sensitisation is not life-threatening, it can be very limiting for persons suffering from it. Depending on the part of the body affected and the severity of the symptoms, ACD may significantly impair the quality of life of the person, sometimes preventing he or she from working or even living normally.

    Its psychological and financial impact on society is very high. As far as its impact on business is concerned, it could be damaging for brand reputation, consequences are:

    • Disruption to Business

    • Negative Press

    • Reputational Damage

    • Loss of Consumer Confidence and Trust

    • Significant Cost Impact: managing the failure, recalling the product, legal settlements, extra testing, loss of sales. If it goes wrong – it will be made public

    The best way to prevent an allergic reaction is to avoid the substance that one is allergic to, although this isn’t always easy or practical.

  • The following four conditions must be satisfied for MACD to occur:

    • The metal in the material must corrode.

    • Metallic material must be in the direct and prolonged contact with skin.

    • The resulting metal must generate a sufficient number of soluble ions (> threshold limit).

    • The metal ions must be absorbed by the skin (allergen metal ions to cross the epidermis into the dermis area of skin) to cause a reaction (Skin Inflammation).

  • The definition of ‘Direct & Prolonged’ contact as proposed by the European Chemical Agency (ECHA):

    Direct contact with the skin. Articles or parts of articles come into direct contact with human skin where the surfaces of the article (or parts of article) are touched or are in touch with the skin.

    Prolonged contact with the skin:

    • Article to be in direct contact with the skin for a minimum of 10 minutes on 3 or more occasions within 2 weeks, or 30 minutes on one or more occasion(s) within 2 weeks

    • “Prolonged contact” needs to be continuous.

  • Metal-induced Allergic Contact Dermatitis (MACD) develops in two stages. The first is the induction or sensitisation phase where the skin gets sensitised following direct exposure to a concentration of the metal allergen sufficient to induce the immune response.

    In the second or elicitation phase, the response is triggered by repeated contact with the specific allergen in the sensitised individual, and this reaction causes a local inflammation recognised as contact dermatitis or eczema. The mechanism of sensitisation and elicitation is defined as below:

    Metals with allergenic properties when come into direct and prolonged contact with skin; they start corroding by reacting with sweat. Provided conditions are right, these allergen ions (i.e., soluble metal ions) so released due to corrosion reaction penetrate the skin through millions of sweat glands located all over our bodies, and hair follicles and cross the epidermis into the dermis area of skin and trigger inflammatory response (through pro-inflammatory cytokine) which leads to activation of dendritic cells (DC).

    The dendritic cells (DC) migrate to the lymph nodes and present the allergen to allergen-specific T cells and initiate an immune response, which leads to the generation of allergen-specific memory T cells. At this stage, the body is said to have been sensitised to that specific metal allergen.

    Note: Lymph nodes are small structures that work as filters for harmful substances. They contain immune cells that can help fight infection by attacking and destroying germs that are carried in through the lymph fluid.

    The sensitisation, often called type IV allergy reaction, is a delayed type of reaction as it takes several days to develop, and it has a non-reversible effect, i.e., once an individual is allergic, he/she is likely to continue to be allergic throughout life to that specific allergen.

    Upon re-exposure to the same allergen in already sensitised individual, memory T cells get activated and cause a local inflammation recognised as contact dermatitis or eczema. This phase is termed as elicitation phase.

    Once a person is sensitised to a substance, even a small amount of it can cause a reaction. Allergic reaction heals after exposure to the offending metal stops.

    Both phases require allergen metal ions to cross the epidermis into the dermis area of skin to cause an immune reaction.

AnchorCert Methodology & Terminology FAQ’s:

  • The AnchorCert Protect methodology identifies the allergenic potential of metal elements present in products and allows only those products deemed to ‘Pass’ to enter the marketplace which considerably reduces the risk of a product causing an allergic reaction to human skin. The ‘Pass’ result from the AnchorCert Protect testing methodology indicates that the component is kind to skin, and it is less likely to cause metal-induced Allergic Contact Dermatitis (ACD) commonly known as skin allergy to an already sensitised individual; thus, preventing both induction and elicitation phase. This means complete freedom from metal allergy.

  • The term ‘Contact Dermatitis’ is used when the skin inflammation is caused by contact with something in its immediate environment. There are two types of Contact Dermatitis - Allergic Contact Dermatitis (ACD) and Irritant Contact Dermatitis (ICD).

  • Epidermis - This is an outer layer of skin, no thicker than a sheet of paper.

    Dermis - This thick middle layer makes up most of your skin. Dermis contains blood capillaries, nerve endings, sweat glands, hair follicles, and other structures.

    Hypodermis – This layer is situated under the skin, which is mainly fat.

    Chemicals/soluble metal ions can be absorbed through millions of sweat glands located all over our bodies, and hair follicles and cross the epidermis into the dermis area of skin to cause an immune reaction.

  • In the sensitisation phase, allergens (e.g., metal ions) penetrate the skin and trigger an inflammatory response (through pro-inflammatory cytokine) which leads to activation of dendritic cells (DC).

    The dendritic cells (DC) migrate to the lymph nodes and present the allergen to allergen-specific T cells, which leads to the generation of allergen-specific memory T cells.

    Upon re-exposure to the same allergen in the elicitation phase, memory T cells get activated and cause skin inflammation and cellular damage.

  • Various European survey results suggest that earrings are the leading cause of metal-induced Allergic Contact Dermatitis, followed by other items of jewellery, buttons on clothing, wristwatches, belt buckles and zips etc. Nickel, Chromium, Cobalt are the top allergens, but certain other metals such as Gold, Palladium, Manganese, Copper etc. are now of growing concern to Dermatologists due to their potential to cause an allergic reaction to human skin. Despite the regulation, people are still becoming sensitised to Nickel.

    The Patch testing is used frequently by dermatologists to identify the cause of allergic reaction to human skin. ESSCA (the European Surveillance System on Contact Allergies) is an EU network; they collect data on patch-tested patients across Europe. A recent analysis by the European Surveillance System on Contact Allergy (ESSCA) network based on 2002–2010 patch test data across Europe, showed a high frequency of skin allergy:

    • 23.4% of the EU population is sensitised to Nickel

    • 9.3% to Cobalt

    • 5.6% to Chromium

    Similarly, the North American Contact Dermatitis Group (NACDG) reported positive responses to Nickel in 19.5%, Cobalt in 8.4% and Chromium in 4.1% of the 5,085 patch-tested subjects.

    The science of nickel sensitisation is well established and understood, but the science of other metal(s) induced allergic contact dermatitis are not well understood. ANCHORCERT PRO RESEARCH PROJECT UNDERTAKEN BY ANCHORCERT GROUP IS ADDRESSING THIS ISSUE.

  • This project was carried out in collaboration with one of the UK’s leading High Street Retailers to develop a testing methodology to assess the reactivity of the metals used in jewellery, watches, eyewear, and other similar metallic accessories including clothing, belt & buckles etc. to identify which of these metals are kind to the skin; at what concentration and which alloy material combination is hypoallergenic. The sole objective was to reduce the likelihood of an adverse skin reaction when the product is used for the intended purpose.

    The resulting methodology, AnchorCert Protect was then developed after intensive in-house research carried out at the AnchorCert Analytical Laboratory, which is part of the Birmingham Assay office, The High Street Retailer adopted this method across their jewellery collection and launched a new range of jewellery, which was designed to be extra kind to sensitive skin. This range was sold in their stores worldwide, and the allergy data was used to make further improvement to the test procedure.

    Our ultimate desire was to considerably minimise the risk of metal-induced skin allergy to provide enhanced consumer protection. This was possible if the probability of AnchorCert Protect compliant jewellery products to trigger an allergic response in an already metal sensitised individual is minimised by scientific means to the lowest possible level, thus preventing both induction and elicitation phase in the majority population. The customer allergy data for 2020 received from High Street Retailer selling AnchorCert Protect compliant products clearly proves that the above objective has been fully achieved.

  • We have studied the patch test data from all over the world to identify the metal allergens responsible for triggering metal-induced Allergic Contact Dermatitis. The following elements have been identified to have the potential to cause an allergic reaction to human skin: Ni, Cr, Co, Au, Hg, Be, Pd, Pt, Mn, Al, Cu, Fe, Mo, Sn, Ti, Zn.

    They are currently being tested under the AnchorCert Protect methodology to identify their potential to cause an allergic response in the product matrix. The product showing an even remote possibility of causing an allergic response to human skin is rejected.

  • The sixteen allergen metals covered within the scope of AnchorCert Protect have been categorised according to relative human skin sensitisation potency as per below:

    High Risk - Nickel (Ni), Chromium (Cr), Cobalt (Co), Gold (Au), and Mercury (Hg).

    Medium Risk - Beryllium (Be) and Palladium (Pd); Platinum (Pt)

    Low Risk - Manganese (Mn), Tin (Sn)

    Extremely Low Risk - Aluminium (Al), Copper (Cu), Iron (Fe), Molybdenum (Mo), Titanium (Ti) and Zinc (Zn).

    The patch test and statistical approach: The primary drivers of conclusions on potency categorisation, are derived from a limited number of dose-response study. Much of the categorisation also depends on judgment & experience. The reader might regard this as expert judgment, but even then, the human patch test data on which this judgement is based contain imperfections and uncertainties that cannot, and never will, be eliminated, thus “caveat emptor”—the use of the data must also involve an acceptance by the reader that these categorisations are the best that can be achieved.

  • It is highly unlikely that the product marked as compliant with the AnchorCert Protect test methodology will cause an allergy to human skin. The compliance results from the above methodology not only provide the complete freedom from metal allergy even to those who were already sensitised, but method also ensures that the product meets the requirements of the EU nickel regulation (section 27 of Annex XVII, REACH) and of General Product Safety Regulation 2005 from a skin allergy point of view. The following four legislations are mainly applicable to jewellery articles, including watches.

    • Nickel Regulation (section 27 of Annex XVII, REACH)

    • Lead/Cadmium Regulation (section 63 & section 23 of Annex XVII, REACH)

    • RoHS Directive (applicable to watches)

    • General Product Safety Regulation 2005

    AnchorCert Protect not only meets the RoHS compliance criteria (excludes Phthalates) applicable to watches their accessories and similar products but also ensures that a product is safe from a skin allergy point of view and from both lead & cadmium poisoning risk by misuse of such articles caused by acute exposure due to ingestion and chronic exposure due to accidental mouthing of articles.

    The AnchorCert Protect methodology also has unlimited scope for expansion; the research is ongoing for including various other regulations and products within its scope. The upgrade will be available as and when accreditation is granted, and software updated accordingly.

    These are the unique part of AnchorCert Protect methodology. No other currently known method has such a distinction.

    Section 1 of the Trade Descriptions Act 1968 prohibits the use of false claims in relation to goods. Section 3 of the same Act extends and defines this prohibition. Thus, a false trade description “is a trade description which is false to a material degree” and “a trade description which, though not false, is misleading... shall be deemed to be a false description”.

    Note: Trade Descriptions Act 1968 has now been replaced with Unfair commercial practices directive 2005/29/EC (“The UCPD”)

    The Local Authorities Co‐ordinating Body on Trading Standards (LACOTS) are of the view that data should be collected before making any such claims. This advice highlights the risks associated with absolute claims given the variabilities involved in metal release related procedures, and the absence of alternative recognised methodology for comparing findings. Instead, and in the absence of a recognised definition, LACOTS recommends the following approach to make an absolute claim about allergy:

    • identifies where every effort has been made to reduce allergenic potential.

    • does not state or imply that all allergy suffers will benefit where this is not the case; and

    • can be supported by appropriate data.

    Keeping the spirit of above recommendation of LACOTS in view we can state that to date we have collated the test data for thousands of items, verified our findings both by customer evidence which includes positive patch testing data from various sources, customer trial by assessing product return data, experimental studies and by applying scientific logic and also in-house laboratory experiments as appropriate and believe that we can substantiate in a court of law the accuracy of the AnchorCert Protect test methodology with regard to meeting the above stated claims.

  • The AnchorCert Protect methodology has been researched “to protect the majority, but not all, of those sensitised” but it can prevent a considerably large population of non-sensitised individuals from becoming allergic to metal allergens.

    A very small part of the population is hypersensitive to certain metals; their skin is hyper-reactive to even considerably low-risk metals and causes varying degree of harshness that is well tolerated by normal skin. Characteristics of the people reporting hypersensitivity to even low-risk metal allergens are generally different from those of people report being allergic to everyday metals. These hypersensitive individuals react to extremely lower concentrations of those metals on the skin contact. Prevention of elicitation in these individuals is important and to be done on a case-by-case basis.

    We anticipate that a large population of the above category will be protected by AnchorCert Protect approach, but we do not wish to make any absolute claims given the variabilities involved.

Testing & Legal FAQ's:

  • The AnchorCert Protect methodology identifies the allergenic potential of metal elements present in products and allows only those products deemed to ‘Pass’ to enter the marketplace which considerably reduces the risk of a product causing an allergic reaction to human skin. The ‘Pass’ result from the AnchorCert Protect testing methodology indicates that the component is kind to skin, and it is less likely to cause metal-induced Allergic Contact Dermatitis (ACD) commonly known as skin allergy to an already sensitised individual; thus, preventing both induction and elicitation phase. This means complete freedom from metal allergy.The AnchorCert Protect test methodology measures the release concentration of the potentially known 16 metallic skin sensitisers and provides an accurate measurement of their sensitisation potential based upon their reaction with novel artificial sweat and the formation of soluble metal ions.

    ‘Pass’ results indicate that the component is kind to skin, and it is less likely to cause metal-induced Allergic Contact Dermatitis (ACD) commonly known as skin allergy to an already sensitised individual; thus, preventing both induction and elicitation phase. This means complete freedom from metal allergy.

    A ‘Fail’ result indicates that the component parts may not be suitable for contact with human skin and may cause metal-induced Allergic Contact Dermatitis (ACD).

    Jewellery and similar items complying with the AnchorCert Protect threshold release limits can be classed and marketed as AnchorCert Protect Compliant.

    The test procedure also ensures that the test sample identified as compliant by AnchorCert Protect methodology shall also be compliant for nickel when tested by EN1811 + A1:2015 method. The success rate has been above 99%.

  • More than 99% of articles passing AnchorCert Protect will also comply with the requirements of the latest version of EN 1811 / EN 12472 and comply with the Nickel Directive. This is a highly acceptable level of certainty from a scientific point of view.

  • Leaching or release of metal ions from metal objects (alloys) in contact with sweat is a multifactorial event that defeats prediction. It depends on several factors, including electrochemical characteristics of the metals /alloys, the supply of sweat and its composition, pH of perspiration (acidity/ alkalinity), temperature conditions, metal element’s ability to form coordinate/ covalent bond and associated bond energy etc. In addition to these properties, other factors such as the size and, in particular, the specific surface area of the metal in contact with skin, the length of time over which exposure takes place, and, of course, the mass or surface area loading of the substance will all play a part in determining the level of soluble metal ions at the metal-skin interface. This is what we call a favourable condition that must exist at the metal-skin interface for the metal to produce biologically active soluble metal ions and trigger skin allergy reaction.

    Aside from the above immediate environmental factors, the microenvironment (grain size) within the particular alloy in contact with a conducting medium (electrolyte, e.g., sweat) is a principal determinant due to the action of electromotive forces prevailing at the interface of atoms with differing electromotive potential.

    It is impossible to change the immediate environmental factors/conditions on the metal-skin interface when the metal object touches consumers' skin. However, the skin allergy could be prevented if we devise a mechanism to control metal release below the safe threshold level; this is possible by adopting the correct metallurgical approach during the manufacturing of the metal objects.

  • Listed below are the possible explanations as to why what appears to be variations in metal release results sometimes occur:

    Each individual case must be viewed independently, but in general, variations in the amount of metal released during an Anchorcert Pro/EN 1811:2015 test may be influenced by several factors as follows:

    • Due to the corrosion/wear/immersion process changing the surface characteristics of the item, it is not possible to test exactly the same article more than once, so direct comparisons in results for exactly the same item cannot be made. Samples from the same batch may be tested and results compared, but they are all individual samples.

    • If articles are plated, particularly with an intermediate interlayer, variable metal release may be observed due to the products themselves being non-uniformly produced as a result of the plating process itself.

    • Differences in use and efficiency of the masking agents used to ‘stop off’ any areas of the item from the test, judged not to be in direct and prolonged contact with the skin.

    • A ‘fail’ result may be obtained for an article to which no allergen metal has been deliberately added because of contamination by allergen metals or other interfering elements during the fabrication process, for example drawing a wire through a stainless-steel die; nickel present in steel die could go onto the surface of wire which apparently had no nickel added during manufacturing. The wire may fail for nickel due presence of nickel which got embedded on the wire during wire drawing process.

    • Surface finish - ranging from highly polished to matt finishes can significantly influence nickel release.

    • Differing surface characteristics, such as discontinuities and porosity.

    • The presence/absence of other elements in the material, such as sulphur can influence surface reactivity and hence metal particularly nickel release.

    • Metallurgical treatments, such as annealing, anodising etc.

    Please note that the rate of allergen metal release from an allergen metal containing material could easily be changed by altering the metallurgical/mechanical properties. The treatment such as annealing at different temperatures for different periods of time can influence the allergen metal release rate. If the material has been properly heat treated and all of the metallurgical aspects which could influence metal release have been considered, then this may cause the material to release metal at below the recommended threshold level, when otherwise it would be expected to fail.

  • We can confirm that, to the best of our knowledge, no other laboratory in the world is offering a similar or matching test. However, to verify our claim concerning minimising skin allergy related incidences even in already sensitised individuals, thus preventing both sensitisation and elicitation phase, you may wish to undertake trials yourselves and compare results findings obtained from AnchorCert Analytical via the AnchorCert Protect Test with results of items from other laboratories if you believe they offer a similar test.

    The Patch testing is used frequently by dermatologists to identify the cause of allergic reaction to human skin. ESSCA (the European Surveillance System on Contact Allergies) is an EU network; they collect data on patch-tested patients across Europe. A recent analysis by the European Surveillance System on Contact Allergy (ESSCA) network based on 2002–2010 patch test data across Europe, showed a high frequency of skin allergy:

    • 23.4% of the EU population is sensitised to Nickel

    • 9.3% to Cobalt

    • 5.6% to Chromium

    Similarly, the North American Contact Dermatitis Group (NACDG) reported positive responses to Nickel in 19.5%, Cobalt in 8.4% and Chromium in 4.1% of the 5,085 patch-tested subjects.

    The science of nickel sensitisation is well established and understood, but the science of other metal(s) induced allergic contact dermatitis are not well understood. ANCHORCERT PRO RESEARCH PROJECT UNDERTAKEN BY ANCHORCERT GROUP IS ADDRESSING THIS ISSUE.

  • Unlike EN1811:2015, which is applicable to metallic components only, the AnchorCert Protect test is applicable to all components made of polymeric1, metallic2 and inorganic non-metallic materials3 including textile and leather intended to come into direct and prolonged contact with the skin or those inserted into pierced parts of the human body.

    Note1*: Polymer materials include polyethylene, polyvinyl chloride (PVC), epoxyresin, polyamide (e.g., nylon), and polystyrene, rubber etc.

    Note2**: Metallic materials may be precious metal alloys, ferrous metal alloys, and non-ferrous metal alloys etc.

    Note3***: Inorganic non-metallic materials may be glass and ceramics etc.

    AnchorCert Protect test methodology covers the metallic & non-metallic parts of the following:

    • Jewellery (fashion/precious), Body Piercings & Accessories

    • Embellishments on Clothing,

    • Finishing Components, including Zips, Poppers, Clasps, Buttons,

    • Decorative parts of garments, other buttons, clothing hooks (such as bra hooks), pins, hair slides, hairgrips, hair clasps, pendants, toe rings,

    • Wrist-watch cases, watch straps, Activity trackers, their straps, and tighteners

    • Belts and belt buckles

    • Metallic/ non-metallic accessories used in textile products, footwear, or leatherwear such as snap hooks, buckles, fastening, padlocks, frames (handbags), buttons, rivets, broaches, eyelets, chains, post assemblies, pins, rings, handles, handbag holders, zips, zip sliders, sequins etc.

    • Cutlery, items of personal hygiene, keyrings, umbrellas, walking sticks, smoking accessories, item of stationery, electronic articles, and mobile phone etc

  • MACD is a disease with the economic and psychological impact on society. It could be damaging for brand reputation, consequences are:

    • Disruption to Business,

    • Negative Publicity,

    • Reputational Damage to Brand,

    • Loss of Consumer Trust and Confidence,

    • Significant Cost Impact: managing the failure, recalling the product, legal settlements, extra testing, loss of sales. If it goes wrong – it will be made public

    MACD has a non-reversible effect; this means once allergic, a person would be likely to continue to be allergic throughout their life. Prevention & Proactive Intervention is the best way forward. AnchorCert Protect is addressing this issue by minimising skin allergy related incidences thereby reducing the economic and psychological impact on society.

  • In our opinion, at least one sample from every batch to be tested and each batch identity to be traceable. It is frequently noticed that although the materials are apparently homogeneous, the test results still vary significantly between batches. In other words, the results obtained for a determinate batch (having an exact and discernible form) are neither representative of, nor can be extrapolated, for other different batches. It is therefore suggested that the samples to be tested must be identified by a code/ batch number that can be traced to the batch. The test certificate, which accompanies the shipping documentation, must make a reference to this code. This is the only way to guarantee the authenticity and traceability between the goods and their associated certificates.

  • In compliance with the GPSD Directive, the supply chain must ensure that only safe consumer products are sold in the European Union (EU); consumers must be informed of the risks that are not immediately perceptible via the use of a suitable warning, e.g.

    CONTAINS COBALT, CAUSES SENSITISATION TO THE SKIN (H 317).

    Sections 28, 29 and 30 of Annex XVII of REACH clearly states that the entire supply chain, including consumers, must be notified, (within 45 days, if requested), if CMR (Carcinogenic, Mutagenic and Repro-toxins) substances are present in an article in quantity exceeding: 0.1% by mass of the mixture.

    Members of the supply chain must be able to prove to the regulatory body (e.g., TS) responsible for overseeing market discipline:

    • That they have ordered products or components free of problems.

    • That they have received products or components free of problems.

    • That they have made sure that they have verified the absence of the problem, this is possible if exposure is adequately controlled to as low a level as is reasonably practicable.

    In the above example, Cobalt as the metal itself is a CMR. When present in jewellery, watches & in similar products, it may form CMR substances such as chlorides or oxides of cobalt due to its migration on contact with body sweat. Such exposure presents the greatest risk to human health if the rate of metal release exceeds the already accepted threshold values set out for those metals in EU/US regulations (safe harbour limit).

    The AnchorCert Protect test methodology has been validated in such a way that it’s ‘compliance report’ would ensure that that any metal allergens and their compounds, if present or formed during the end use of the product would cause less risk to human and comply with the requirements of General Product Safety Directive (GPSD) from a ‘Skin-Sensitisation’ point of view.

  • Nickel is a common metal often combined with other metals to create alloys with increased hardness and resistance to corrosion. However, the presence of nickel in certain products which are intended to come into direct and prolonged skin contact may cause sensitisation of humans to nickel and may lead to allergic reactions. Nickel released is regulated under EC 1907/2006 REACH Annex XVII, Item 27. The latest version of EN 1811 is to be used to verify the conformity of the products to the regulation.

    Anyone wishing to place items on the market must recognise that they have a legal obligation to ensure that items meet the requirements of the REACH regulation. The responsibility for ensuring that all items conform is placed upon retailers, importers, wholesalers, and manufacturers.

    It is a defence for a person charged (for ‘product liability’ & breach of statutory duty) to show that he took –

    • All reasonable steps; and

    • Exercised all due diligence to avoid committing the offence.

    All reasonable steps - these are proactive precautions, e.g., setting up systems/procedures of control.

    Exercising all due diligence - this is reactive and means making sure the systems work.

    The onus is on the seller to prove “all due diligence”. The seller needs to be able to prove, through a paperwork audit trail that they have complied with legislation. This will entail obtaining certification from suppliers to guarantee compliance and also “appropriate” random testing of the products being sold.

    The supplier of a product which is found not to comply with the nickel regulation is committing an offence under the Consumer Protection Act. Penalties can be up to six months imprisonment or fines of up to £5000. Also, there are likely to be far higher financial penalties in terms of personal injury claims and damage to the reputation of the business.

    The General Product Safety Directive (GPSD) EC/2001/95 exists to ensure that only safe consumer products are sold in the European Union (EU). The GPSD covers the provisions for consumer products in its finished state that are not covered by specific sector legislation. For example, Cobalt as metal is a known allergen but it is not covered by any specific EU legislation. In such situation skin allergy due to cobalt will be monitored according to provisions of the General Product Safety Directive (GPSD) EC/2001/95 which advocates that only safe products enter the market.

    Consumers must be provided with the information required to evaluate the risks of the product during its normal period of use. The jewellery product must be free of CMR substances. The supply chain is responsible for assessing the risks and they must be guaranteed that the safe product has been placed on the market by test certificates from an accredited laboratory. All written information related to manufactured items must be filled and available to the authority that requires it.

    Other consequences are:

    • Disruption to Business,

    • Negative Publicity,

    • Reputational Damage to Brand,

    • Loss of Consumer Trust and Confidence,

    • Significant Cost Impact: managing the failure, recalling the product, legal settlements, extra testing, loss of sales. If it goes wrong – it will be made public (e.g., Argos, Reebok, Mattel cases)

    Prevention & Proactive Intervention is the best way forward. AnchorCert Protect addresses this issue by minimising skin allergy related incidences thereby reducing the economic and psychological impact on society.

  • In court, there is no need for the prosecution to prove an intention to commit an offence. Onus is on defendant to prove that he/she took all reasonable steps and showed all due diligence to avoid committing the offence. There are no written rules as to what this means for an organisation, what is reasonable depends on the size and resources of the business. A large business, for example, must do more [Ref.: Garrett v Boots the Chemist].

    • A company with many shops must exercise control at all levels. The directors speak and act as the company their subordinates do not [Tesco Supermarkets Ltd v Nattrass].

    • Relying on the reputation and experience of wholesalers is not a precaution - elementary testing was (Sherratt v Geralds the American Jewellers).

    • Even in a fair and proper relationship with the enforcing authority, it is not possible to ‘shuffle off’ responsibility onto a friendly enforcement officer. Failure to test imports was not ‘reasonable’ (Taylor v Lawrence Fraser (Bristol) Ltd).

    • Control systems must include adequate checks, that are recorded, with instructions given to staff and staff training given in the systems (Baxters Butchers v Manley)

    • TESTING (Rotherham Metropolitan Borough Council v Raysun):

    • The number of tests must be sufficient.

    • Test results must be reported, and they must be considered.

    • Blanket assurances from a supplier are not enough, there must be positive acts to justify the defence (Riley v Webb)

    • Can be delegated, key criteria are: Competence & Independence (Amos v Melcom)

    • In contract

    • In negligence

    • In ‘product liability.’

    • Breach of statutory duty

    In ‘product liability’ it was irrelevant whether the hazard had come to the notice of the producer before the incident occurring (Abouzaid v Mothercare (UK) Ltd)

  • In deciding what is reasonable for due diligence, the following needs to be considered:

    • Risk assess the product – likely use, potential danger and what potential harm could it do?

    • Risk assess the supplier – established record or unknown, QMS, accredited, recommended, type of business, other customers?

    • Consider previous test results – high rate of failure?

    • Create a decision tree for your business to assess each product or supplier against, grade them to quantify risk.

    • Establish a sampling plan with different levels according to risk, based on both product and supplier

  • Nickel is the most common cause of Allergic Contact Dermatitis of the skin. This may cause minor allergic irritation for most individuals, but some people may experience a severe significant reaction.

    The main problem with nickel arises for nickel sensitised patients who develop dermatitis. Nickel can easily permeate through the skin resulting in a perpetuation of dermatitis. As nickel is such a universally found substance, it is almost impossible for sufferers to avoid contact with nickel. As a result, long-term side-effects occur.

    The purpose of the Nickel Regulations is twofold:

    To prevent people from becoming sensitised to nickel.

    To reduce the risk of prolonged and direct contact with articles with a high level of nickel release which could trigger an allergic reaction.

    It is estimated that 15% of people in Europe are nickel-sensitised, so the danger of a Customer suffering bad reactions from a non-conforming product is significant. Subsequent legal action is almost inevitable.

    To ensure that products comply, they must be tested to the relevant British Standards stipulated in the legislation i.e., BS EN 1811 and BS EN 12472. Other screening tests are a useful part of a due diligence procedure, but legally all items must pass the relevant test stipulated in the Regulations.

  • No limit has been set for the nickel content of items in direct and prolonged contact with the skin.

    The requirements in the Regulations refer only to Nickel release.

    There is no simple relationship between Nickel content and nickel release, so it is not possible to state which alloys will be compliant, based on their composition alone.

    The amount of nickel released from a Nickel-containing alloy depends on several factors, such as the thickness/uniformity/porosity in plating and metallurgical aspects including homogeneity etc. Providing the plating is sufficient to prevent nickel being released at below the figures quoted in the Regulations - for post assemblies, they will be compliant if they release nickel at less than 0.2 µg/cm2week (<0.35 data-preserve-html-node="true" µg/cm2week with 46% uncertainty), and for other products, in order to be compliant, the rate of nickel release from each individual part of the item coming into direct and prolonged contact with the skin must be equal to or less than 0.5 µg/cm2/week (<0.88 data-preserve-html-node="true" µg/cm2week with 46% uncertainty), then the actual nickel content is not the determining factor.

    It is, therefore, necessary to test finished items containing Nickel, in order to establish the level of Nickel release and hence compliance or otherwise.

    The assumption made by anyone that item will fail to comply with the REACH Nickel regulation without testing the items for Nickel release is not professional or acceptable in the eye of law. Items must be tested by EN1811:2011 + A1:2015 method and if it fails due to the presence of Nickel in the alloy then legal action could be taken but not until failure is proven.

  • We can help ensure that you conform to REACH regulation. Our UKAS accredited laboratory offers all necessary REACH tests, and our professional staff are experts in this field and closely involved in the latest developments. AnchorCert Group, which is part of the Birmingham Assay Office, is involved in these developments and commits itself to keep our Customers up to date with any changes they need to be aware of.

  • The General Product Safety Directive (GPSD) EC/2001/95 ensures that only safe consumer products are sold in the European Union (EU). The GPSD covers the provisions for consumer products in its finished state that are not covered by specific sector legislation. Consumers must be provided with the information required to evaluate the risks of the product during its normal period of use.

    Anyone wishing to place items for sale on the market must recognise that they have a legal obligation to ensure that items are safe during the intended use by the consumer and meet the applicable requirements of the EU Regulations. The responsibility for ensuring that all items conform is placed upon retailers, importers, wholesalers, and manufacturers.

    There is a growing concern within the EU and worldwide about skin sensitisation of the general population from exposure to metallic elements present in jewellery, watches, eyewear, piercing, dental implants alloy materials and also from metallic elements present in chemicals used in textile and leather articles, such as clothes and footwear. Once a person is sensitised to an allergen, they must avoid exposure to the allergen for the rest of their life in order to prevent allergic reactions. Furthermore, data show that there is no difference in the prevalence of contact allergy between children and adults. This means that a person can get sensitised at a very young age and can be affected during their entire life.

    If the skin sensitisation is caused by its exposure to metal allergens, then it is termed as Metal Induced Allergic Contact Dermatitis’ (MACD) which is a disease with an economic and psychological impact on society. It could be damaging for brand reputation and the potential consequences of are disruption to business, negative publicity, reputational damage, loss of consumer trust and confidence and trust as well as a significant cost impact from managing the failure, recalling the product, legal settlements, extra testing, loss of sales. If it goes wrong – it will be made public.

    MACD has a non-reversible effect; this means once allergic likely to continue to be allergic throughout life. Prevention & Proactive Intervention is the best way forward.

    Sensitisation to nickel (Ni) is the main cause of metal induced Allergic Contact Dermatitis (ACD). However, there are several other transition metals that are now of growing concern amongst dermatologists for their capability to act as allergens under certain circumstances. The research undertaken by AnchorCert Analytical on the sensitisation and contact dermatitis, along with In-vitro tests carried out in-house suggest that in addition to Nickel (Ni), Chromium (Cr) and Cobalt (Co), Allergic Contact Dermatitis (ACD) could also be initiated by other elements such as Aluminium (Al), Gold (Au), Beryllium (Be), Copper (Cu), Iron (Fe), Mercury (Hg), Manganese (Mn), Molybdenum (Mo), Palladium (Pd), Tin (Sn), Titanium (Ti) and Zinc (Zn) providing favourable conditions existed. None of these potential allergens, other than Nickel, is covered by EU legislations.

    The AnchorCert Protect test methodology measures the release concentration of the known 16 potential metallic skin sensitisers (Ni, Cr, Co, Au, Hg, Be, Pd, Pt, Mn, Al, Cu, Fe, Mo, Sn, Ti, Zn) and provides an accurate measurement of their sensitisation potential based on their reaction with a novel artificial sweat and the formation of soluble metal ions. The test procedure also ensures that the test sample identified as compliant by AnchorCert Protect –shall also be compliant for Nickel when tested by EN1811 + A1:2015 method.

    The purpose of the AnchorCert Protect test methodology is fourfold:

    • To prevent people from becoming sensitised to sixteen potentially known metal allergens.

    • to reduce the risk of prolonged and direct contact with articles with a high level of metal release from sixteen known metal allergens which could trigger an allergic reaction.

    • To ensure product conforms to entry 27, Annex XVII (REACH) which imposes restrictions on the use of Nickel in all post assemblies which are inserted into pierced parts of the human body and articles intended to come into direct and prolonged contact.

    • The compliance from AnchorCert Protect method also implies that the product meets the General Product Safety Regulation 2005 from a skin allergy point of view.

    The AnchorCert Protect test methodology has been validated in such a way that it’s ‘compliance report’ would ensure that that sixteen potential metal allergens, if present or formed during the end use of the product would cause less risk to human from a ‘Skin-Sensitisation’ point of view. The AnchorCert Protect compliant product will also meet the General Product Safety Directive (GPSD) EC/2001/95 requirements from a ‘Skin-Sensitisation’ point of view.

    Contrary to EN1811:2015 which is applicable to metallic components, the AnchorCert Protect test is applicable to all components made of polymeric, metallic, and inorganic non-metallic materials including textile and leather that are intended to come into direct and prolonged contact with the skin or those inserted into pierced parts of the human body.

    The compliance results from the AnchorCert Protect test methodology implies that in the majority of people, the article will not trigger an allergic reaction even in an already sensitised individual, thus preventing both induction and elicitation phase. This means complete freedom from metal allergy in the majority population. No other currently known method has such a distinction.

  • The purpose of the General Product Safety Directive (GPSD) EC/2001/95 is to ensure that only safe consumer products are sold in the European Union (EU): The GPSD covers the provisions for consumer products in its finished state that are not covered by specific sector legislation. Consumers must be provided with the information required to evaluate the risks of the product during its normal period of use.

    Anyone wishing to place items on the market must recognise that they have a legal obligation to ensure that items are safe during the intended use by the consumer and meet the applicable requirements of the EU Regulations. The responsibility for ensuring that all items conform is placed upon retailers, importers, wholesalers, and manufacturers.

    Those who are responsible for enforcing the legislation will focus their attention on EU importers, wholesalers and retailers who must ensure their products comply and are safe. If one of your products causes a problem in the future, you will need to be able to prove that you took “all reasonable steps” and exercised “all due diligence” to avoid committing an offence. Note the word “all” in these statements.

    Carrying out a few tests at random or the production of an unaccredited test certificate will not be accepted as fulfilling the requirements of ‘Due Diligence’, if a product sold by you is subsequently found not to meet the criteria set out in the legislation.

    It is only possible to establish a ‘Due Diligence Defence’ if all the following criteria are met:

    • The defendant has a Preventative System in place to demonstrate that all reasonable and practical steps have been taken to ensure that products comply with legislation and are safe during their intended use. This should include clear specifications of your requirements and some product testing to ensure products conform.

    • The defendant can demonstrate that the Preventative System has been regularly monitored to ensure that it remains effective in order to avoid an offence being committed.

    • There is a reasonable and innocent explanation as to how the offence occurred.

  • There cannot be any certainty that a product does not contain any known metal allergens and conforms to the REACH Regulations without it undergoing full testing. However, if you have full knowledge of the components and methods of production, these guidelines may be used as an indication of which products does or does not contain metal allergens and are most likely to conform to REACH or other relevant legislation. Please note that the AnchorCert Analytical does not take any responsibility for the interpretation of these guidelines or any subsequent consequences arising from this information.

    Yellow Carat Gold Alloys are likely to conform, as metal allergens including Nickel are not normally present as a deliberate addition in EU. However, Nickel, Cobalt or Palladium may be present in the traditional plating solution used to “flash plate” so beware.

    White Gold Carat Alloys may not conform as nickel or palladium can be deliberately added to “whiten” the alloy. Rhodium plating can reduce the amount of Nickel or Palladium being released but this depends upon the plating being of a sufficient thickness and can also be affected by other factors e.g., porosity in the plating.

    Platinum Alloys are unlikely to be a problem. Platinum is a highly reactive transitional metal which easily complexes with donor groups in amino acids to form a complete antigen. The platinum compounds eliciting hypersensitivity are confined to a small group of ionic complexes containing reactive halogen ligands.

    Silver Alloys commonly used in jewellery articles in themselves are likely to conform, as any known metal allergens including Nickel are not normally present as a deliberate addition. However, if a Nickel or Palladium diffusion barrier has been used beneath a top layer of fine silver, then the final product may not conform depending upon the thickness of the layer etc. If Silver is plated with Cobalt to give an antique look, then it is highly likely it may cause skin allergy if conditions are favourable.

    Costume Jewellery could contravene the regulations if nickel is used as a plated layer beneath the surface layer, or if nickel is present in the plating solution used to plate the surface layer. Other known metal allergens covered under ‘AnchorCert Protect’ test methodology if present may potentially cause skin allergy if conditions are favourable.

    Watches will depend upon the materials selected for the components and any subsequent treatments.

  • Although contact allergy to Gold is frequent, complex interplay between gold and the human body sweat is still poorly understood. The ionisation of elemental gold is essential to induce contact allergy and to elicit Allergic Contact Dermatitis (ACD). It is understandable that gold when present in a solution as a soluble or complex ion may cause contact dermatitis. However, keeping the electrochemical nobility of gold in mind, it is not clear how metallic gold or gold alloys present in jewellery and similar products would react with body sweat at a rate sufficient to elicit an allergic reaction in gold-sensitised people.

    In a double-blinded study where 60 individuals with gold contact allergy were instructed to wear for 8 weeks either gold-coated (n = 30) or titanium nitride (n = 30) earrings, there was a significantly higher number that developed ear lobe reactions to the gold-coated earrings (12 vs 5). In ear lobe dermatitis caused by gold, scanning electron microscopy and X-ray microanalysis had shown small dense fragments containing gold.

    During the AnchorCert Protect research study we observed that the gold plating of gold-plated articles tends to react with artificial sweat and produce soluble gold ions when it is not in perfect uncharged equilibrium with its substrate, due to the difference in electrode potential. Soldered/welded assemblies of non-plated jewellery items introduce the macro potential difference between solder and gold base alloy which could also cause the release of gold ions into sweat.

    Gold, due to its nobility, hinders the production of significant amounts of soluble gold ions. If the quantum of gold release will be above or below the threshold limit required to trigger an allergic reaction in gold sensitised individuals, will depend on the size of potential difference which in turn depends on the size of macro defects.

    We have scientific evidence to prove that gold does release into novel artificial sweat, but we are unable to fully characterised its mechanism and exact conditions under which such release take place. There is a need for a scientific investigation to understand better the formation of soluble gold ion in sweat solution, gold allergy and allergic contact dermatitis induced by gold.

    We are continuing broader studies, conducted more rigorously, which are needed to firmly answer the questions raised in our paper titled “Gold Allergy: Differentiating Myth from Reality” written by Dippal Manchanda regarding the condition & mechanism of Gold dissolution in bodily fluids.

    Platinum is a highly reactive transitional metal which easily complexes with donor groups in amino acids to form a complete antigen. The Platinum compounds eliciting hypersensitivity are confined to a small group of ionic complexes containing reactive halogen ligands.

  • Look for the AnchorCert Protect sticker on the product or request information from the seller or supplier. A list of high street retailers granted a licence to sell AnchorCert Protect’ compliant jewellery available on our website www.anchorcertprotect.com.

  • AnchorCert Protect test methodology offered by the Anchorcert Protect Laboratory of the Birmingham Assay Office has been witnessed by Assessors from the United Kingdom Accreditation Service (UKAS) and been seen to meet the requirements of ISO 17025 – ‘General requirements for the competence of testing and calibration laboratories’ and has therefore been included on our scope of accreditation. The test results will be supplied as a full Report on a UKAS accredited certificate. These certificates will be accepted throughout the EU to meet nickel regulation requirements.

  • The Anchorcert Group Laboratory is accredited by UKAS (the United Kingdom Accreditation Service) to ISO 17025 standard and follows rigorous Quality Assurance and Quality Control Practices.

  • EN1811/ or AP Test: One finished article as it will be displayed or sold. However, in case of earring, minimum two pairs of earrings to meet the surface area requirements.

    AP-Pb-Cd/ or AP-RoHS test: Two finished article as it will be displayed or sold.

  • Any of the signatory of the test report.