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QUESTION: What are the Australian standards for jewellery charms imported from China containing lead? 08/01/09 Victoria, Australia

I was wondering if someone could help me. I make jewellery charms and was looking to purchase some alloy charms from china. I discovered that some of these charms contain lead. When I queried this the seller told me that " lead alloy pendants contains 0.6PPM for each 1000pcs. It is an international standard, so it doesn't cause much harm to human body."

I was wondering what the Australian standards for jewellery containing lead are and if the quantities they have told me are safe?




----- Original Message -----

From: tasha

To: The LEAD Group

Sent: Thursday, January 15, 2009 11:04 AM

Subject: RE: What are the Australian standards for jewellery charms imported from China containing lead?

Hi Elizabeth,

Thank you very much for getting back to me. The information was very helpful. I have not yet decided if I should buy the charms. But I am very grateful to you for looking into it for me.



ANSWER: Jan 14 2009

Dear Natasha,

there is NO standard in Australia (or anywhere to my knowledge), which limits the amount of lead in non-children's jewellery. This means that metal jewellery which contains lead up to 100% or 1,000,000 ppm (parts per million) can be legally sold in Australia. However, if the jewellery could be considered to be a "toy" (eg, if it is marketed to children under 14 years of age), then it would need to comply with the Australian toy standard (AS/NZS ISO 8124.3:2003) which requires that any toy or toy component produces less than 90 mg/kg (milligrams per kilogram) lead migration, when tested in acid.

When I rang the Australian Competition and Consumer Commission (ACCC) this morning to ask how they distinguish between "children's jewellery and children's toy jewellery", the Info Centre woman answered: "a judge could probably give you a definition; I doubt you would find that definition on any government website because it is common sense and we probably have never had a problem with it and I really don't know what to say to you."

For information on the control of lead in toys in Australia see "Product safety bulletin June 2010: Lead and certain elements in children's toys and finger paints"

The result you have provided is clearly not a result of testing by the methodology of the Australian Toy Standard. It is likely that the supplier was trying to convince potential purchasers that the charms had been tested in accordance with the new US Children's Products Law, entitled Consumer Product Safety Improvement Act of 2008. A children's product is regarded in the US, as one intended for, or marketed to children under 12 years of age.

According to the "Accreditation Requirements for Third Party Conformity Assessment Bodies To Test To the Requirements for Lead Content in Children’s Metal Jewelry as Established by the Consumer Product Safety Improvement Act of 2008" at ;

labs etc will need to be accredited by the US Consumer Product Safety Commission "to assess conformity with the 600 parts per million (‘‘ppm’’) and 300 ppm lead content limits in metal and metal alloy parts of children’s metal jewelry established by the Consumer Product Safety Improvement Act of 2008."

According to "CPSC Clarifies Requirements of New Children’s Product Safety Laws Taking Effect in February" at

"Under the new [US] law, children’s products with more than 600 ppm total lead cannot lawfully be sold in the United States on or after February 10, 2009, even if they were manufactured before that date. The total lead limit drops to 300 ppm on August 14, 2009."

If the Chinese metal alloy charms you are purchasing were actually tested by a US-accredited lab, the result should be available on the lab's letterhead and would not be in the Chinese English you have been given: "lead alloy pendants contains 0.6PPM for each 1000pcs."

In other words, I would be highly sceptical of the stated result, without seeing the actual lab report.

Having said that, it is certainly true that a result of 0.6 ppm lead in metal alloy charms is a very good result which could be regarded as virtually lead-free and therefore lead-safe. But the risk is, unless you are shown the lab result; that no test may have been carried out, that if a test was carried out, either that the product you are buying was not the product that was tested, or the lab may not be accredited by any organisation, or the result was not reported properly. For example, the result may have been 0.6% lead which someone has wrongly stated as 0.6ppm. A result of 0.6% lead when properly converted, becomes 6000 ppm lead, or 10 times the new US legal limit.

A result of 0.6 ppm lead denotes quite sophisticated testing equipment with very low detection levels so on that basis also, I would question it's veracity.

I truly believe that the lead content of all jewellery should be controlled in Australia and everywhere else. For example, even if your jewellery is only intended to be sold to adults, if the lead content of the charms is high, the risk is that a child could suck on the charms on mummy's bracelet or actually swallow a charm and be slowly lead poisoned. A US child died of lead poisoning after ingesting a leaded charm from a bracelet that came free with a pair of Reebok shoes [Ref: "Death of a Child After Ingestion of a Metallic Charm" at ]

Would you like me to investigate which Australian lab is certified to carry out lead analysis of metals? If you did your own testing at a certified lab, you'd then know if the charms comply with the new US Law and you could rest easy when selling your jewellery. Based on the cost of lead analysis of other types of samples, the cost is likely to be something between $40 and $110 per sample.

I hope this helps and look forward to hearing back from you.

Yours Sincerely

Elizabeth O'Brien

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