This guide explains what each one requires, what is still unclear for pins, and what to ask a supplier for.

Key Takeaways

  • The General Product Safety Regulation (GPSR) has applied since 13 December 2024 to consumer products, and the company selling under its own name or trademark counts as the manufacturer.
  • Makers outside the EU need an EU responsible person, and every product needs identification, contact details and a technical file kept for 10 years.
  • REACH caps nickel release at 0.5 micrograms per square centimeter per week for articles in direct and prolonged skin contact, tested to EN 1811.
  • A 2017 ECHA draft guideline lists keychains as in scope. It does not clearly settle lapel pins, and it puts sport medals outside.
  • Ask for test reports per model and plating, not a general declaration.

In This Article

What Does the GPSR Require for Pins and Keychains?

The GPSR, Regulation (EU) 2023/988, has applied since 13 December 2024 and covers consumer products. The Commission’s guidelines for businesses (Notice C/2025/6233, November 2025) do not name pins or keychains, so the reading that a pin or keychain sold to consumers is in scope is ours. The guidelines are not binding. A lawyer should confirm how they apply to your product.

The points that matter for merchandise:

  • Who is the manufacturer. The guidelines define it as the person who manufactures a product, or has it designed or manufactured, and markets it under their own name or trademark. A club or brand that orders pins and sells them under its own name is the manufacturer for GPSR purposes.
  • EU responsible person. A product can only be placed on the EU market if a responsible person is established in the EU. That can be the manufacturer, an importer, an authorized representative with a written mandate, or a fulfilment service provider.
  • Identification and contact data. The product needs a type, batch or serial number, the manufacturer’s name, trade name or trademark, and a postal and electronic address. If the product is too small, the information can go on the packaging or in an accompanying document, such as a backing card or bag.
  • Internal risk analysis and technical documentation. Both must exist before the product is placed on the market, per product model, and be kept for 10 years. Units with a different composition or color count as separate products.
  • Online listings. A product offered online must show the same identity data, a picture and any warning.
  • Accidents. Serious accidents are reported through the Safety Business Gateway.

Products that complied with the previous directive and were placed on the market before 13 December 2024 can stay on sale under a transition rule (Bird & Bird).

What Does REACH Say About Nickel?

REACH Annex XVII, entry 27, limits nickel in two cases. Post assemblies inserted into pierced parts of the body must release less than 0.2 micrograms per square centimeter per week. Articles intended to come into direct and prolonged contact with the skin must not exceed 0.5. Coated articles must keep release at or below 0.5 for at least two years of normal use, and the test method is set out in European standards (entry 27 text).

Nickel matters for plated pins and keychains because it is a strong sensitizer that can cause allergic reactions, and plating layers can contain it. The practical consequence is that the plating specification belongs in the technical file, which is why our guide to quality control for metal merchandise asks for plating in microns.

Is a Keychain or a Pin Covered by the Nickel Limit?

The law does not define prolonged contact. An ECHA draft guideline from 2017 (CA/76/2017, a copy hosted by the Austrian chamber of commerce) gives a working definition: potentially more than 10 minutes on three or more occasions within two weeks, or 30 minutes on one or more occasions within two weeks.

What the draft says about our products:

  • Keychains, key rings and key fobs are listed among articles used by hand.
  • Lapel pins and badges are not clearly settled. The draft lists “pins” next to needles and thimbles and “pins, clasps” among garment decorations, which does not answer the question for a pin badge.
  • Sport medals appear in a list of items outside the scope, because contact is long on the day of the award but not repeated many times.

This is a draft, and we found no final version. Treat it as guidance on how authorities may think, not as the law. If a pin sits against skin, for example on a lanyard worn under clothing, assume the limit applies.

What About Lead and Cadmium?

Entry 63 limits lead in jewelry articles to less than 0.05 percent by weight, and entry 23 limits cadmium in jewelry components to 0.01 percent (Annex XVII). Whether pin badges count as jewelry is not settled in the sources we found, and the lists name brooches and cufflinks. Entry 63 also has a rule for articles that can be put in a child’s mouth, which covers small metal items sold to the general public.

Enforcement shows how seriously authorities treat heavy metals in accessories. Safety Gate alerts in December 2025 and early January 2026 flagged jewelry with cadmium, nickel and lead, mostly from China (Squire Patton Boggs summary). We found no alert for a pin badge or keychain, but the search tools we used could not query the Safety Gate database directly.

What Should You Ask a Supplier for the GPSR File?

This list is our own synthesis, so confirm it with a lab or lawyer:

  • an EN 1811 nickel release report for the specific model and plating, from an accredited laboratory
  • lead and cadmium content results for each material part, including base metal, plating and enamel
  • a material specification naming the base metal, the plating layers and the enamel type
  • a statement tying batch or lot numbers to the tested model
  • input for the GPSR file: composition, a risk assessment and a product identification scheme, such as a batch code on the backing card
  • the name of the EU responsible person if the factory is outside the EU

Prices and lead times for tests vary, so ask for quotes. Our guide to designing an enamel pin for production covers the plating and enamel choices that feed into this specification. Am Ball, an officially licensed design, production-management and quality-control agency for sports collectibles, briefs its partner factories on specifications like these.

Frequently Asked Questions

Does the GPSR apply to pins and keychains?

Consumer products are in scope, and the guidelines do not name pins or keychains, so a pin or keychain sold to consumers should be treated as covered. Items sold only to businesses for internal use are likely outside, but check your case.

Who is the manufacturer when a club orders pins?

A club or brand that sells pins under its own name or trademark is the manufacturer under the GPSR guidelines, even if a factory makes them.

Do pins need a batch number?

The product needs a type, batch or serial number. If it is too small, the number can go on the packaging or in an accompanying document.

Is there a nickel limit for pin badges?

Entry 27 applies to articles in direct and prolonged skin contact. The 2017 ECHA draft lists keychains but does not clearly cover pin badges, so ask for an EN 1811 test report for plated pins that touch skin.

How long must the technical file be kept?

For 10 years after the product has been placed on the market.

Conclusion

Treat the GPSR as a duty for whoever sells under their own name, and treat nickel as a plating question that a test report answers. Put both into the specification before production starts, and keep the file.

Reach out to discuss specifications and test requirements for pins and keychains.