Every so often I get an inquiry from a jewelry designer or friend about finding a factory in China to manufacture jewelry to be sold in the United States. There are a very large number of options out there that you can identify through resources such as Alibaba.com and Globalsources.com, but the first thing I caution every designer is to familiarize themselves with the host of regulations that limit toxic metals in jewelry, primarily lead and cadmium. There have been several episodes in the last 10 years where environmental interest groups have purchased low cost jewelry at retail stores and had them tested for toxic metals, only to discover that they far, far exceeded allowable levels in the U.S. Most of these problem products are manufactured in China and India. Lead and cadmium are the most commonly encountered toxic metals.
This subject came up again last year in the form of a press release from the California Department of Toxic Substances Control, which has just fined four retailers in Los Angeles more than $200,000 for violating California standards on toxic metals in jewelry and for misleading consumers about the lead content of jewelry sold by these retailers.
So perhaps it's time for a quick refresher on the requirements for toxic metals that apply to jewelry. There are a whole host of additional requirements that apply to toxic metals in childrens products, so those standards should be consulted for children's jewelry.
At the federal level, the Consumer Product Safety Improvement Act, passed in 2008, gives the Consumer Products Safety Commission authority to regulate toxic metals in jewelry, along with regulatory powers for a number of other toxic chemicals in consumer products. California has a number of laws that apply to toxic metals in consumer products generally, and this state has also passed a law specific to jewelry, naturally called the California Metal-containing Jewelry Law. Several other states, such as Minnesota, have consumer products laws that regulated toxic metals in consumer products. Needless to say, with the number of requirements out there, it's important to keep up with changes and new requirements in this area so that designers can develop specifications for manufacturers to ensure levels of lead and cadmium are sufficiently low to meet U.S. standards.
Any contract manufacturing activity should incorporate quality standards, quality testing, and provisions for returning items that do not meet design specifications. Designers can access resources to help with quality and contracting by joining a trade association, many of which help with subcontract manufacturing arrangements.
- California Metal-containing Jewelry Law
- California facts about lead in jewelry
- California facts about cadmium in jewelry
- Recent enforcement activities by the California Department of Toxic Substances Control
- European Union REACH restrictions
- Fashion Jewelry Trade Association Guidance
- Example jewelry supplier specification from Macy's Department Store