Does the Directive apply to Brooches?
The only part of a brooch that could normally come in direct and prolonged contact with the skin is the brooch pin. This would normally not happen on a heavy brooch or kilt pin as these items are expected to be warn on an outer garment with an other layer of cloth between the skin and the pin. It becomes more complicated on a light brooch as these may be worn with the pin touching the skin in which case the directive would apply to the brooch pin only.