A finished garment can pass a fabric screen and still fail because the zipper was never in the test plan. Customs and brand RSLs treat a zipper as an article made of homogeneous materials: dyed tape, metal or plastic elements, plated slider, painted puller, PU film, rubberised puller. One report on “the zipper” that mixed those parts is not a report. TrimGem University files zipper chemistry next to snap nickel and cord azo because they ship in the same carton, and the Guangzhou catalogue will keep adding those SKUs — the regulations already apply.
EU REACH: limits versus communication
Annex XVII is the hard stop. Zipper lines that actually fail:
- Nickel release (entry 27) on skin-contact metal — elements, slider, puller. Limit 0.5 μg/cm²/week by EN 1811:2023. Coated metal is worn first by EN 12472, then EN 1811. Total nickel in the alloy is not the EU test.
- Lead, cadmium, Cr(VI) in metal and plates.
- Phthalates in soft PVC pulls and some coated tapes (typically 0.1%).
- Azo colourants on dyed tape that can cleave to listed amines.
- PAHs on some rubber or painted pulls.
SVHC is a moving candidate list (hundreds of entries). Above 0.1% w/w in an article, communicate down the chain; above 1 t/year of that SVHC in articles, SCIP notification enters the conversation. A 2019 letter is not a 2026 SVHC statement.
Metal zippers are a nickel and heavy-metal programme. Moulded POM is a plasticiser and colourant programme. Coil is a tape-dye and (if coated) film programme. Do not one-report them.
United States, UK, kids
CPSIA (children 12 and under): total lead 100 ppm in substrate, 90 ppm in paint and coatings — including a painted puller. Phthalates on plasticised parts. Children’s zippers are also a small-parts / pull-off story: ASTM D2061 strength so a tab does not become a choke hazard. A CPC is the importer’s document from a CPSC-accepted lab.
California Proposition 65 is a warning law; brand RSLs therefore treat zipper metal as if nickel and lead were already in court.
UK zipper product testing has moved with BS EN 16732 (strengths and reciprocating life). UAE humidity programmes add salt spray so the chain does not rust onto pale cloth. Australia watches sharp edges and chin-guard / top-stop geometry on infant garments.
Chinese kidswear (GB 31701) still wants no accessible sharp points; moulded plastic stops are the usual zipper answer.
How a test is actually run
Name zipper type and end use (skin contact or not). Send a BOM split — tape, elements, slider, plate, coating — and 5–10 pieces per colour / plate. Different colours are different dye lots; different plates are different chemistries. Use an ISO/IEC 17025 lab. Annex XVII fails mean a material change, not a footnote.
Frequent misses: fabric tested, zipper not; SVHC list frozen; nickel pass on a new plate that fails after wear; mixing a coil report onto a metal PO.
What TrimGem asks on the sampling note
Market (EU / US kids / adult), chain family, whether the puller is skin-contact, and which mill article. Needle detect is a brand control, not a REACH clause, and still belongs on metal-stop programmes. Compliance is lot-specific. Change the plater, retest.
A zipper is not “accessories, so skip chemistry.” It is often the only metal on a cotton dress.