Entry 23 of Annex XVII to REACH - Cadmium and its compounds

According to paragraph 10 of entry 23 of Annex XVII to REACH cadmium shall not be used or placed on the market if the concentration is equal to or greater than 0,01% by weight of the metal in metal parts of jewellery. Does this concentration threshold apply to each metal component of an item of jewellery or to the jewellery item as a whole?

With reference to paragraph 10 of the Annex to Commission Regulation (EU) 494/2011 amending entry 23 of Annex XVII of the REACH Regulation (cadmium) the concentration threshold of cadmium applies in each metal part of jewellery. The wording used by the legislator, i.e. "metal parts of the jewellery and imitation jewellery" implies that each metal part is relevant; therefore in order to determine if the restriction applies the calculation of the concentration in this case is to be done for each metal part. Therefore, if there are several metal layers as coatings on the surface of an inner (metallic) part of the jewellery these should be regarded as integral part of the metal part and the concentration limit of 0,01% is calculated for this whole metal part. In case the inner part is not metal, but the coating is made of metal layers, this coating is regarded as one metal part. If the jewellery article contains several metal parts, each of them should comply with the concentration limit.