New EU regulations for manufacturers

[PewDrop]

Following in the wake of the Californian regulations regarding product safety and hazardous substances the EU are bringing in similar regulations.

http://www.theassayoffice.co.uk/mailers/pdfs/LEAD_Legislation-mailer.pdf

I made this post in my support forum and thought that I would share it with you:..

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Who knows where this will lead to, definitely higher prices, because each manufacturer will have to test before selling on.
Take a simple pendant necklace with a simple joining catch at the back, here is a breakdown of components..

Pendant
Jump ring to attach pendant to a bail.
Bail to attach the jump ring to the necklace cord.
Cord.
Jump ring at each end of cord to connector. (2)
Connector parts (2)

There are 8 parts in this simple necklace that would need testing by the company that made each part and the company that assembles the parts into the Jewellery (me)
Even the cord needs testing if its not a natural colour in case the dye contains lead.
I would need 5-6 tests on this batch of necklaces if some of the components were identical (jump rings in this case)
I would also need 2 lead tests carried out, content and release.
Here are the fees charged,

http://www.assayoffice.co.uk/Analytical-Services/Jewellery_Testing_Fees.asp

For this simple necklace I would need to pay £109.92 inc vat.
Unless I make massive batches it just is not profitable, I could pass the costs on to you though, but seeing that I only make batches of 5-10 at a time that would make a simple necklace £11-£22 more expensive to make.

I would think also that eBay would eventually demand proof of testing before allowing items to be sold when they learn of the regulations.

So, what do you make of it?

Just a thought, wouldn't it be good PR for a government to pass a law that protects the voters from harm?

It will most likely get passed with a great deal of backslapping self-righteous publicity.

Manufacturers will then be under the magnifying glass for compliancy.


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I know that there active beaders and jewellery makers on here and wondered what you thought of this?

I amsure that our jewellery expert Baa will know of this and can give her opinions on it.

[scotserve]

Pewdrop
In a similar vein - In 1995 I was manufacturing computers - very high spec 1 off machines for specific purposes, I was on MOD approved list and most of our clients were Blue Chip and government, at one time a lot of Londons West end stages had lighting systems controlled by our machines.
Then came along EU shite and electromagentic radiation and CE certifications, because every machine we built was one off each machine needed to be certified, Marconi was the only local place to get this done with a lead time of 9 months and a cost of £800 per machine - because 90% of our customers could only buy machines that complied after Jan 96 the company had to fold.

I fought and fought hard about this for 2 years prior as I knew the impact it was going to have but failed to get local enterprise agencies or governement to acknowledge  or help

Beware the man that wears the EU hat

[Baa]

AFAIK these are proposed changes and there is room for individual member states to make their own policies for this. It could be some time before this is actually introduced in the UK depending on the efforts and desires of the industry.

What I'd like to know is whether this legislation is purely for jewellery manufactured in the EU or includes jewellery sold in the EU. If it's for jewellery sold in the EU it could well be beneficial for EU manufacturers.

[scotserve]

If it's for jewellery sold in the EU it could well be beneficial for EU manufacturers.

I often hear this argument in relationship to EU policy however IMO the economics do not stack up

A is a seller external to the EU
B is within the EU

Lets assume A is already able to be competitive with B under current regulation
Now estimate the new regulation will increase costs by say 20% If A is already able to undercut B a 20% increase will benefit A more as their costs had to be less in the first place, so in effect the EU seller is worse off 

[Baa]

Anything I say right now on this would be pure speculation, and while I may seem to argue over a bit of string being dark grey or medium grey, I do like to have some colour swatches under my belt first (believe it or believe it not LOL).

So there ya go, I don't know but I'm not ruling out that it might well be fantastic any more than it might be a disaster. In all probability it will be just another rule to comply with half heartedly like EU cookies regs.

[PewDrop]

 In all probability it will be just another rule to comply with half heartedly like EU cookies regs.

That made me laugh, I immediately thought of the Jaffa cake scenario, is it a cake or a biscuit?

I have thought about this long and hard and for me it will be business as usual with products that I know contain no lead, but then there is the Swarovski problem, I believe that crystal glass will be exempt even though it has an extremely high lead content. So, do I use crystal or not?

As usual EU fuddle.

[Baa]

I can't find the actual quote from Swarovski but the suggestions are that lead crystal isn't considered much of a risk. http://www.kandicorp.com/cpsia.htm

[PewDrop]

Apparently if you smash it into little pieces and then smash it again and ingest the powder you will suffer harm 


Here is where the buck is being passed..

Recognizing that the regulatory landscape changes often, it remains the responsibility of our business customers to assure that their use of crystal in jewelry and other products is consistent with all applicable requirements.

[Baa]

Edited to clarify.

How is that passing the buck any more than saying we don't accept responsibility for omissions or errors in pricing?

[PewDrop]

My reason for saying that is that if there was a situation that could arise during manufacturing a piece of jewellery where there might be a chemical reaction with the crystal to cause lead release, then the jewellery maker would be responsible for knowing about it, not Swarovski.
For instance, if I glue a crystal on to a cabochon and the glue causes a reaction with the crystal that releases lead, then it's my responsibility, not Swarovski's.
I was thinking hat if Swarovski know of any ways of using their product that cause lead release then they should be published and not left to chance.

On re-reading their statement, what I thought at the time is probably different to what they were intending, they were talking about regulation requirements, I wasn't. I'll get my coat........


I blame the lead, when I was a child, I played with lead soldiers painted with lead based paint, lived in a house that was probably painted with lead based paint, drank water that had been delivered to the house in lead pipes and breathed in the fumes of cars whose petrol was stuffed with lead, I attached lead weights to fishing lines and closed them over by biting them. When I was 21 (40 years ago this year) I was given a pewter tankard by the landlord of my regular pub, it was a tradition, the tankard was left in the pub and used for quaffing ale out of, not the fizzy chemical crap that's called beer today, but ale that was delivered in wooden barrels and pumped out by hand pumps, that tankard is still in my position and is a dull grey colour, showing a high level of lead content.

Did me no harm,


apparently.