Compliance guidance. Regulatory text is from the HSE UK REACH list of restrictions (entry 27, nickel) and the HSE authorisation list and a Defra decision (chromium trioxide), read on 7 November 2026. The spreadsheet's version log ends in 2022, so check the current text on legislation.gov.uk and with a test house or your adviser. This is not legal advice; confirm with the relevant authority. The studio coordinates manufacture through partner workshops and does not certify finishes or test for nickel release.

At a glance

FinishLookWear and repair (reported)Regulatory flag
Bright chromiumCool, bright, mirror-likeA film a fraction of a micrometre thick over nickel (reported); hard, but a scratch can reach the nickelPlater's chromium trioxide bath (Annex 14); nickel beneath
Nickel, polished or satinWarmer than chromiumPlated layer; dulls and can be re-polished, or stripped and replatedEntry 27 if it touches skin
Black nickelDark grey to blackA thin coloured deposit; shows wear at edges (reported)Nickel compound; entry 27 if it touches skin
GoldYellow gold look, set by the alloy and thicknessA thin layer wears through to what is beneath; thickness decides lifeOften over nickel (reported); entry 27 if it touches skin
Rose goldPinker, copper-rich gold lookAs gold; colour names vary between suppliersAs gold
PVD alternativeMany colours, thin vacuum filmVery thin, hard; not platingSee the PVD sheet

Wear and repair behaviour is general finisher knowledge and is not a sourced test. The regulatory flags are from the HSE list (entry 27) and the HSE authorisation list, read 7 Nov 2026.

What plating is made of

Plating is metal laid on metal in a bath. The part is dipped in a solution and a thin layer of another metal is deposited on its surface. Decorative plating is built in layers: the base metal, one or more underlayers, and a very thin top layer that gives the colour. Finishers report that bright chromium sits over a nickel layer, and that gold is often put over a nickel or similar barrier layer. The top layer is thin; the underlayer carries most of the corrosion resistance. Our plating and coating thickness sheet gives the micrometre figures and the polish-through risk.

Why layers matter for regulation. Wear on a thin top layer can expose the underlayer. If that underlayer is nickel and the part is touched every day, nickel can reach the skin. That is why the regulation looks at the finished, worn article and not at the top layer alone, and why a handle in a busy hotel is a different case from a hidden bracket. See high-touch hospitality metal finishes.

The behaviour in the at-a-glance table is general finisher knowledge, not a sourced test result; ask the partner for a sample and a written build-up. Finish names are not standardised: see ironmongery finish codes for how the same code can mean different finishes.

Plating or PVD. PVD is a vacuum-deposited ceramic-type film, not a plated layer, and some PVD processes still need a nickel and chromium plated underlayer on some metals. See PVD coatings explained.

Section through a plated part, with a worn spot and the two regulatory flagsSide view of a base metal with a nickel layer and a very thin decorative top layer. A worn spot has taken the top layer away and exposes the nickel. An arrow marks skin contact. Two boxes below name the two regulatory flags: nickel release at the surface of the part, and the authorisation needed by a plater who uses a chromium trioxide bath. Schematic, layers drawn far thicker than real.Skin contact12341Base metal2Nickel layer3Thin decorative top layer4Worn spot: nickel exposedFlag A: nickel releaseat the surface of the part, where skintouches it (entry 27, Annex 17)Flag B: chromium trioxide authorisationat the plater, whose bath contains Cr(VI)(Annex 14, UK REACH)
Section through a plated part: base metal, nickel layer and a thin decorative top layer, a worn spot that exposes the nickel, and the two regulatory flags. Schematic, layers drawn far thicker than real. Original drawing by Make Bespoke Studio.

Nickel release: UK REACH entry 27

Entry 27 of the UK REACH list of restrictions controls nickel. The HSE list reproduces entry 27 (Nickel, CAS 7440-02-0, and its compounds). It says nickel shall not be used in post assemblies inserted into pierced ears and other pierced parts of the body unless the rate of nickel release is below 0.2 micrograms per square centimetre per week. It also says nickel shall not be used in articles intended for direct and prolonged contact with the skin, such as earrings, necklaces, bracelets and chains, anklets, finger rings, wrist-watch cases, watch straps and tighteners, and rivet buttons, tighteners, rivets, zippers and metal marks in garments, if the rate of release from the parts in contact with the skin is more than 0.5 micrograms per square centimetre per week.

The clause that hits plated parts. Paragraph 1(c) applies the limit to those articles where they have a non-nickel coating, unless the coating is enough to keep nickel release under the limit for a period of at least two years of normal use. A plated finish over nickel must therefore keep working as a barrier for two years in use. Paragraph 3 says CEN standards are the test methods for showing conformity. BSI lists BS EN 12472:2020 as the method for simulating accelerated wear and corrosion before testing nickel release from coated items, and secondary sources report BS EN 1811:2023 as the nickel release test method, adopted by the European Commission in the Official Journal of 20 December 2023; neither standard was read.

Where a handle, tap or rail fits. Entry 27 names jewellery and clothing fittings as examples, introduced by the words “such as”, and door handles and rails are not among them. Whether a particular article counts as being in direct and prolonged skin contact is a question for the partner, a test house or a regulator, not for this sheet. If you are asked, ask the partner for a nickel release test report on the finished article, with wear conditioning where relevant, or a written reason why entry 27 does not apply.

Ways to avoid the question. Specify a finish on a base that has no nickel underlayer, such as solid brass or stainless with a PVD finish applied directly, if the partner and coating house can do so and confirm it in writing. Do not assume this: some processes still use nickel, and PVD on brass may use plated underlayers. Ask what is under the visible layer.

UK REACH Annex 17 entry 27 (nickel): a reading pathThree boxes in a row. First: is the article intended for direct and prolonged skin contact, such as jewellery or watch cases, or a post assembly inserted into a pierced body part? Second: the limits printed in entry 27 are 0.5 micrograms per square centimetre per week for skin contact and 0.2 for piercing posts. Third: a non-nickel coating must keep the release under the limit for at least two years of normal use. A note says door handles are not among the listed examples but the list begins with the words such as, so whether a handle counts is a question for the partner and a test house.1 Is it in the entry?Entry 27 lists piercing posts,earrings, necklaces, bracelets,rings, watch cases and straps,and garment rivets, zips andtighteners that touch skin2 What is the limit?Skin contact articles:0.5 micrograms per cm2 per weekPiercing posts:0.2 micrograms per cm2 per week(migration limits)3 Coated nickel?A non-nickel coating over nickelmust keep release under thelimit for at least two years ofnormal use of the article(entry 27, 1c)Handles are not among the examples, but the list is open.It says "such as", so ask the partner and a test house whether a handle counts.Test methods are CEN standards (entry 27, paragraph 3): see BS EN 1811 and BS EN 12472.
A reading path for entry 27 of the UK REACH list of restrictions, as printed in the HSE list. Original drawing by Make Bespoke Studio.

Chromium trioxide and the plater

Chromium trioxide is on the UK REACH Authorisation List. The HSE list shows chromium trioxide as entry 16 in Annex 14, which means a UK business may use it only under an authorisation. Chromium trioxide contains hexavalent chromium, Cr(VI), the form of chromium to which its carcinogenic and mutagenic properties are attributed. Traditional bright chrome plating uses it in the bath.

An example of how it works. A Defra decision of 29 July 2025 (AFA055-01) grants one UK plater an authorisation for the industrial use of chromium trioxide for functional chrome plating with decorative character on metallic objects. It sets a 12-year review period, so the authorisation ends on 30 June 2034 unless a review report is filed by 30 December 2032, and it imposes monitoring conditions. The decision is addressed to the applicant and to that use, so an authorisation belongs to a named plater for a stated use; it is not a general permission for chrome plating.

What a specifier can do. Ask the partner who will plate the parts, and ask for the plater’s authorisation or the statement that it works under one. Ask whether the process uses a chromium trioxide bath. Some platers use other chemistry for decorative chromium finishes, and then the question changes; ask. If the plating is done outside the UK, ask for the partner’s own compliance statement for the supply route. We did not read how GB and EU authorisations interact for imported plated articles, so do not assume either way.

Wear and repair. Decorative plating can be repaired only by stripping and replating, which repeats the regulatory steps. A finish that will be touched, scratched or cleaned hard every day may be better as solid metal with a lacquer or a PVD film; see lacquered or unlacquered brass and copper and cleaning and maintaining metal finishes.

Specifying plating

What to write in a brief. Name the base metal, the build-up of layers (underlayers and top layer) and the minimum thickness of each as a number from the plater’s certificate (thickness sheet), the colour to a sample and its batch approval (sample approval), the nickel release evidence if the part touches skin, and the plater’s chromium trioxide position. Link the finish to the metalwork brief and the anodising or powder coat options when plating is not a must.

Warranty and care. Ask the partner what the plating is warranted against and for how long, in writing, and for the care instructions that keep the finish valid. Abrasive cleaners and polishes wear plating faster, and plating cannot be touched up on site.

Specification wording

Paste into your schedule or specification and replace anything in [square brackets] with your own figures. Wording is a starting point: your specification governs.

Plated finish
[Part ref] in [base metal], plated [finish name, e.g. nickel / chromium / gold] with build-up [underlayers and top layer in order]; minimum thickness of each layer [ ] micrometres, shown on the plater's certificate; colour to approved sample [ref]. Plating route: partner to name the plater and state whether a chromium trioxide bath is used; evidence of the plater's authorisation where one is required. Repair and care instructions to be supplied; no abrasive polish.
Nickel release
Parts in direct and prolonged contact with skin [list refs, e.g. handles, rails]: partner to provide a nickel release test report on the finished article to [BS EN 1811 with wear conditioning to BS EN 12472 where relevant] showing release below [the UK REACH entry 27 limit], or a written reason why entry 27 does not apply. Test house and date to be named. Evidence before manufacture is approved.

Terms used on this page

Nickel release
The rate at which nickel leaves an article in contact with the skin, measured in micrograms per square centimetre per week.
Annex 14
The UK REACH Authorisation List: substances that may be used only under an authorisation, including chromium trioxide.
Cr(VI)
Hexavalent chromium, the form of chromium in chromium trioxide to which its carcinogenic and mutagenic properties are attributed.
Underlayer
A plated layer beneath the visible top layer, often nickel, that carries corrosion resistance and surface quality.
Polish-through
Wear that removes the thin top layer so the layer beneath shows or is exposed.

All metalwork terms

Standards and sources

Questions we are asked

Is chrome plating legal in the UK?

Chromium trioxide is on the UK REACH Authorisation List (Annex 14, entry 16), so a UK plater may use it only under an authorisation. A Defra decision of 29 July 2025 shows how one is granted to a named plater for a stated use. Ask your partner which plater is used and what it holds.

What is the nickel release rule?

Entry 27 of the UK REACH list of restrictions limits nickel release from articles in direct and prolonged contact with skin to 0.5 micrograms per square centimetre per week, and from piercing posts to 0.2. A coating over nickel must keep release below the limit for at least two years of normal use.

Does a door handle need a nickel release test?

Handles are not among the examples listed in entry 27, but the list says 'such as', so it is not exhaustive. Whether a handle counts is a question for the partner and a test house or regulator. Ask for a nickel release report or a written reason why it does not apply.

How long does gold plating last?

It depends on the thickness and the wear. A thin gold layer wears through to the layer beneath, and there is no standard life to quote. Ask for the build-up and the thickness in micrometres, and consider solid metal with a lacquer or a PVD film for high-touch parts.

Is PVD better than plating?

They are different processes. PVD is a very thin vacuum-deposited film used on many colours, and plating is a bath-deposited layer. Compare them for wear, repair and the regulatory questions on this sheet; see the PVD sheet.

Download the factsheet

A two-page A4 PDF with the plated section, the finish table, the nickel release path and the chromium trioxide questions, with paste-in wording.

Factsheet TL-MET-49 v1.0 (PDF)