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Main causes of nickel contamination in costume jewelry plating

I buy costume jewelry directly from factories in Asia. A few factory's jewelry fail the European Nickel regulations because random components (extension chain, jump rings, an eye-pin) have Ni elution results of up to 20 micrograms / cm2 / week.
Are there any obvious places the plating factories should look in order to eliminate these random failures e.g. raw material (normally brass), tools used to handle the products, any of the plating materials (copper base plate, tin-copper second plate, either gold or silver top plate).
Julian Kelly

2006

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2006

It seems to me that there are 3 possible reasons a part could fail this test--
1). The one particular item is actually nickel plated.
2). The test is overly sensitive, subject to contamination, or improperly conducted.
3). Some trace amount of nickel has contaminated a non-nickel bath or tool.

I could certainly be wrong, but I have listed the three reasons according to which I think is most likely, whereas you seem to have already dismissed what I would suspect as the more likely explanations :-)

Good luck.

Ted Mooney, P.E.
Striving to live Aloha
finishing.com - Pine Beach, New Jersey