Sellers on Amazon may Need to Provide the Declaration of REACH Conformity or Testing Reports

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 relevant declaration of REACH compliance or testing reports applicable to your products.

What is REACH and how does it apply to products?

When selling products on Amazon, you must 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 the limits of certain chemical substances are exceeded, 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 restrictions, along with the complete list of restrictions are listed in REACH's Annex XVII, this 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 can include jewellery and imitation jewellery, to be placed on the wrist, ankle and neck etc.

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

Declaration of REACH compliance

This document is created by the manufacturer and confirms that their products are compliant under REACH. 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 the Market Surveillance Authority, a REACH testing report must be provided to show compliance.

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 may help you with questions regarding regulatory requirements on the Service Provider Network page.

Our Services

  • SVHC Testing
  • SVHC Notification
  • SVHC Annex XVII Testing

Contact Us

Dean Winder,

Regulatory Consultant

TEL: +00 353 1 477 3706

E-mail: dean.winder@cirs-reach.com

Further Information

Amazon Official Notice