New Requirements for Nickel Release Limits for Amino Acid Chelates in EU REACH Annex XVII
Jul 14, 2026

On July 13, 2026, the European Union officially issued Regulation (EU) 2026/1189, introducing new nickel release limit requirements for related products containing aminoborates and having nickel coordination structures, and clearly stating that enforcement will be mandatory starting from January 1, 2027. This change involves application areas such as cosmetics, feed additives, and industrial auxiliaries, and is worthy of continuous attention from export enterprises, formulation and compliance teams, inspection service organizations, and business personnel responsible for technical document management, as it is directly related to testing methods, declaration materials, and compliance preparation for entering the EU and related markets.

What exactly has been clarified by this rule update

According to the information provided, on July 13, 2026, the Official Journal of the European Union (OJEU) issued Regulation (EU) 2026/1189, which involves new nickel release limit requirements for aminoborate-type nickel complexes added to Annex XVII of EU REACH.

The regulation clearly states that, starting from January 1, 2027, cosmetics, feed additives, and industrial auxiliaries containing aminoborates that have nickel coordination structures must be tested in accordance with EN 1811:2023, and the nickel release amount must not exceed 0.5 μg/cm²/week.

The provided information also points out that this requirement will directly affect Chinese export enterprises dealing with aminoborates, as well as compliance declarations, SGS testing plans, and updates to CE/UKCA technical documentation.

The impact extends beyond the products themselves and reaches multiple business links

Changes in the export declaration process are more direct

From an industry perspective, the trade and export enterprises directly facing the EU market will be the first to be affected, because the new requirement has already specified the implementation date, applicable product categories, and testing basis. Its impact is mainly reflected in whether the declaration materials can prove that the relevant products meet the nickel release limit, and whether existing materials need to be supplemented or retested. What is even more worth noting at present is that enterprises need to quickly determine whether their export products contain the condition of “aminoborates and nickel coordination structures”; otherwise, problems may arise later in delivery and customs clearance support materials.

Formulation, raw materials, and manufacturing teams need to verify structural attributes in advance

For raw material procurement enterprises, processing and manufacturing enterprises, and teams responsible for formulation management, the impact is not only reflected in final testing, but also in front-end identification. In analysis, if the product belongs to cosmetics, feed additives, or industrial auxiliaries, and involves related coordination structures, it is necessary to confirm the product’s structural attributes and applicable scope as early as possible, and then determine whether it needs to enter the EN 1811:2023 testing pathway. The business impact is mainly reflected in raw material selection, sample testing arrangements, production batch management, and external technical explanations.

Testing and compliance service chains will be adjusted accordingly

For testing service providers, compliance consulting agencies, and teams responsible for technical document organization, the changes brought by this rule are mainly reflected in testing plans and document system updates. The provided information clearly mentions that SGS testing plans and CE/UKCA technical document updates will be affected; therefore, relevant service links need to make corresponding adjustments around testing standards, report applicability, and document version management. For procurement parties and downstream customers, attention may also shift to whether suppliers have already prepared materials in accordance with the new requirements.

Where companies should focus their attention now

First confirm whether the product falls within the scope of the new requirement

In practice, what enterprises need to do first is not a generalized response, but to sort out their own product catalog and confirm whether it belongs to cosmetics, feed additives, or industrial auxiliaries containing aminoborates, and whether it involves nickel coordination structures. This step determines whether subsequent testing, document updates, and customer communication processes are needed.

The testing path needs to be scheduled backward from the implementation date

Since the regulation clearly states that it will be mandatory from January 1, 2027, relevant enterprises need to work backward from the delivery cycle, sample submission schedule, and document preparation cycle. In analysis, the focus is not only on “whether to test,” but also on practical execution issues such as “when to complete the test,” “whether existing reports are still applicable,” and “how to connect old and new batches.”

Technical document updates cannot remain only at the testing report level

The provided information mentions that CE/UKCA technical document updates will be directly affected, which means enterprises cannot simply understand the response as adding one more test report. What is more worth attention at present is whether related technical documents, compliance declaration materials, and supporting documents submitted to customers need to be updated synchronously while maintaining consistency in wording.

Communication with customers and service organizations should start as early as possible

From an observational perspective, for export business, customer communication and service coordination are equally critical. Enterprises need to communicate with testing organizations, compliance consultants, customer procurement teams, or quality teams as early as possible to confirm material requirements, testing arrangements, and document update timing, so as to reduce delivery pressure caused by centralized handling near the implementation date.

This is more like a clear compliance tightening signal landing in practice

As an observation, this information should not be understood merely as a routine standard update. It has already specified the regulation number, applicable categories, testing standard, limit requirements, and implementation date, so it is more appropriate to understand it as a compliance requirement that has entered the execution-preparation stage rather than a policy direction still at the discussion level.

At the same time, it can be observed that the impact of this change is currently concentrated mainly in three areas: specific product identification, testing arrangements, and technical document updates. Whether it will further expand to broader application scenarios, the current provided information does not offer more confirmation; therefore, the industry still needs to continue tracking subsequent official statements and actual implementation pathways.

At this stage, it should be treated as a highly actionable compliance point

In summary, the signal released by this information is relatively clear: for related products involving aminoborates and containing nickel coordination structures, EU market access requirements are moving from principle-based constraints toward measurable and verifiable specific indicators. For relevant enterprises, it is now more appropriate to treat this as a compliance point that needs to be quickly incorporated into product screening, testing arrangements, and document update plans, rather than a long-term change to be handled after further market feedback.

Basis of this article and follow-up verification direction

This article was generated based on the user-provided news title, event occurrence time, and event summary. The core information includes the regulation release date, regulation number, implementation date, applicable categories, testing standard, limit requirement, and the direct impact on compliance declarations, SGS testing plans, and CE/UKCA technical document updates.

For such information, it is usually also necessary to combine official announcements, standard organization documents, enterprise disclosures, industry association information, and authoritative media reports for continuous verification. Since the input did not provide a specific official source link, the original reference link and subsequent execution details still need continuous checking. Follow-up areas worth focusing on include: whether the official authorities release further clarification pathways, how the related testing and document update requirements are implemented in actual business, and the specific connection arrangements at the execution level for different product categories.