This is an area where a small misunderstanding creates real risk, so it is worth being precise about what is being measured and about who decides what applies. Nothing here is legal advice, and nothing here states what any supplier holds.
Release is not the same as content
A part can contain nickel and release very little, or contain less and release more, depending on the surface, the coating and its condition. The property that matters for skin contact requirements is release, not bulk composition.
This is why a material declaration alone does not answer the question, and why a coating that changes with wear can change the answer over the product’s life.
Why prolonged contact is treated separately
Requirements in this area generally distinguish parts in prolonged contact with skin from parts that are not. A snap fastener on the inside of a waistband and a decorative plate on the outside of a bag are in quite different positions.
When describing your product, identify which parts are in prolonged skin contact. It is the deciding fact and is often not obvious from the part list alone.
Wear, and testing after simulated use
Coatings wear. Requirements in this area commonly consider the part after simulated wear rather than only when new, because a surface that changes in service changes what it releases.
For a buyer, the practical consequence is that coating durability is part of this question, not a separate cosmetic one.
Establishing what applies to you
Which requirement applies depends on the market you sell into, the product category and how the part is used. That is a determination for you and your compliance advisers to make; a supplier can tell you what a part is and what testing has been done, but cannot decide your regulatory position for you.
Once determined, state the requirement by name and scope in the enquiry. A named scope can be quoted and verified; a general request for compliance cannot.
What documentation actually shows
A test report covers specific samples, tested by a specific method, on a specific date. It is evidence about those samples, not a permanent property of every part a factory makes.
Check the scope, the date and the sample identification on any report you are given, and agree how often verification is repeated for ongoing production.
What to state in your enquiry
Which parts are in prolonged skin contact, the market you sell into, the specific requirement you must meet as determined by your advisers, whether testing after simulated wear is required, and the documentation you need at delivery.
This guide states no limits, thresholds or test results, and makes no statement about any supplier’s certifications. It describes the shape of the question so you can ask it precisely.
Skin-contact requirements concern release rather than content, treat prolonged contact separately, and often consider the part after wear. Determine what applies with your own advisers, state that scope in the enquiry, and read the scope and date on any report you receive.