REACH,Amazon,Declaration,Testing,Reports,Inspection,Conformity

Recently, Amazon has strictly inspected declaration of REACH conformity or heavy metal testing reports of Amazon Europe products. Products that have not submitted relevant documents within the specified time will face the risk of being suppressed. Earlier, Amazon issued an important notice requiring sellers to provide declaration of REACH conformity or heavy metal testing reports. The notice states that if you sell products on Amazon Europe, you must comply with all applicable EU and local laws and regulations, as well as Amazon policies that apply to these products and product information.

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.

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 (migration limit):

Less than 0,2 μg/cm²/week for jewellery intended to be inserted into pierced ears and other pierced parts of the human body

No greater than 0,5 μg/cm²/week for jewellery intended to come into direct and prolonged contact with the skin

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, please feel free to contact us.

How does REACH impact the products that I sell?

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.

How do I obtain approval to sell Jewellery?

Amazon’s policy requires all sellers of jewellery to have one of the safety documents listed below. Upon request, you must promptly submit one of the required safety documents for each ASIN or model number you want to list.

(1) 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.

(2) 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.

Applicable regulation

Threshold

Type of document

REACH – Annex XVII n. 23, 27, and 63

Cadmium 0.01% (100 mg/kg)

Declaration of REACH conformity; or

Lead 0.05% (500 mg/kg)

Testing reports.

Nickel migration limit:

 

Less than 0,2 μg/cm²/week for jewellery intended to be inserted into pierced ears and other pierced parts of the human body

 

No greater than 0,5 μg/cm²/week for jewellery intended to come into direct and prolonged contact with the skin

 

All sellers 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 CIRS Service Provider Network page.

Who is responsible for obtaining these documents?

If you are contacted, you are responsible for providing these documents to Amazon. If you are the brand owner or importer, you should already have these documents on hand. If you are a reseller, you may have to ask your supplier for these documents. If you (or your suppliers) do not have these documents available, you may have to undertake testing yourself to demonstrate conformity.

Why do you choose CIRS C&K Testing?

It is worth noting that the preferred solution recommended by Amazon [Declaration of REACH conformity] is the same as the [REACH compliance assessment report & certificate] solution provided exclusively by CIRS C&K Testing for a long time! Using conformity assessment reports + certificates instead of ordinary test reports can help people understand product compliance conclusions in seconds and quickly clear customs.

CIRS C&K Testing can provide customers with professional REACH regulations on SVHC substances of high concern and Annex XVII restricted substances testing, and as the only legal representative (OR) under REACH, we can provide SVHC agency notification and SCIP notification services for non-EU companies. Based on the understanding and in-depth research of REACH regulations, CIRS C&K Testing can also provide REACH regulations training for customers, and implement a one-stop comprehensive solution for consulting, testing and certification. If you have any needs or questions, please contact us at test@cirs-group.com.