Sellers on Amazon may Need to Provide the Declaration of REACH Conformity or Testing Reports
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Important: If you sell products on Amazon, you must comply with all applicable EU and local laws and regulations, as well as Amazon policies applicable to those products and product listings. To sell certain products on Amazon, you are required to provide the declaration of REACH conformity or testing reports.

What is REACH and how does it apply to products?

When selling products on Amazon, you need to ensure compliance with Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). Under REACH, articles (i.e., finished products) cannot be sold if they exceed limits for certain chemical substances, such as heavy metals. Please click to know more information about REACH.

Annex XVII n. 23, 27 and 63 of the REACH Regulation sets specific restrictions on the maximum allowable content of cadmium, nickel and lead applicable to articles with metal components:

Substance

Applicable threshold for restriction

Cadmium

equal to or greater than 0.01% by weight

Nickel

rate of nickel release less than 0.2 μg/cm²/week (migration limit)

Lead

equal to or greater than 0.05% by weight

Detailed information on this restriction, along with the complete list of restrictions as listed in REACH's Annex XVII, is available on the ECHA website. We encourage you to consult your legal counsel if you have questions about the laws and regulations concerning your product.

How does REACH impact the products?

To comply with applicable laws and regulations, Amazon prohibits the sale of articles that exceed the restriction levels specified in Annex XVII. For certain products, Amazon requires a REACH declaration from the manufacturer or testing reports showing adherence to the REACH limits for cadmium, nickel and lead. These products include:

  • Jewellery and imitation jewellery to put on the wrist and ankle, such as bracelets and anklets
  • Jewellery and imitation jewellery to put on the neck, such as necklaces
  • Jewellery and imitation jewellery that pierce the skin, such as earrings and piercings
  • Jewellery and imitation jewellery that are put around fingers and toes, such as rings and toe rings

In addition, products may be physically tested by Amazon or Market Surveillance Authorities, which could lead to requests for further information or suspension of sales, so it is important for you to have all required compliance documents available for all products in order to request a reinstatement.

Declaration of REACH conformity

This document is a declaration of conformity with REACH drawn up by the manufacturer. The declaration should also address any Substances of Very High Concern (SVHCs) contained in the product. The declaration of REACH conformity can either be self-certified by the manufacturer or can be issued to the manufacturer by a third-party testing organisation.

REACH heavy metals testing reports

These testing reports show compliance with REACH’s heavy metals thresholds for all components of your product (see the following table). If your product failed a physical test by Amazon or a Market Surveillance Authority, we will require a REACH testing report.

Table 1. Overview of thresholds and document types

Applicable regulation

Threshold

Type of document

REACH – Annex VII n. 23, 27 and 63

  • Cadmium 0.01% (100 mg/kg)
  • Lead 0.05% (500 mg/kg)
  • Nickel has a migration limit 0.2 μg/ cm2/week
  • Declaration of REACH conformity; or
  • Testing reports.

All selling partners are responsible for ensuring that their products and listings comply with all applicable laws and regulations. By applying to sell or reinstate these products, you certify that all information you submit is true. You can find a list of external consultants who might help you with questions regarding regulatory requirements on the Service Provider Network page.

Our Services

SVHC Testing

SVHC Notification

SVHC Annex XVII Testing

If you have any needs or questions, please contact us at test@cirs-group.com.

Related Information

REACH Regulation

REACH Annex XVII

Candidate List of 209 SVHCs

Amazon Notice