Reach Testing for Jewellery Sellers


#1

I’ve received a notification for three of my jewellery products, that they need REACH testing (metals testing) certificates or they will be removed from sale.

All of my products at Amazon Handmade are metal - either sterling silver or pure copper, and therefore I expect it is only a matter of time before my entire shop is shut down.

Small handmade sellers working with pure metals cannot possibly REACH test every single metal item they make and sell and therefore I presume this is Amazon Handmade saying that small crafts people who work with metal, are no longer welcome to sell at Amazon Handmade.


From REACH:

" Inspections for the eighth major Forum enforcement project have started. The project will check whether companies selling hazardous substances, mixtures, biocidal products and articles online in Member States and EEA countries comply with REACH, CLP and the Biocidal Products Regulation.

Helsinki, 20 January 2020 – The eighth major Forum enforcement project (REF-8) concentrating on the online sale of substances, mixtures and products has entered its operational phase and will run until 31 December 2020. 29 countries will participate in the project.

The project will target products for the general public and professionals, available in private companies’ webshops and in marketplace platforms, such as Amazon and eBay.

Inspectors will check if buyers are informed about the existence of hazardous substances before the purchase is completed and if particular aspects of the regulations are fulfilled. This can be checked by controlling the advertisement of a chemical product or by purchasing products and subsequently analysing them."


As usual Amazon are being very heavy handed by demanding a REACH certificate for products made from pure copper and 925 sterling silver, neither of which have ever been considered a chemical hazard.


Listings removed
#2

Hi, I’ve had the same message and what would appear to four randomly chosen items. Really not sure what to do about it. They are all earrings. One of the pairs has surgical steel fittings, the others have silver plated hooks… as does a vast vast amount of handmade earrings sold on Amazon Handmade.
I would not know how to even go about testing these items, … I’ve been selling for donkey’s year, on Ebay and have also sold on Etsy. I have never had a problem reported. Don’t know what to do? My instinct is to remove them just to save the hassle, and to ensure my account isn’t de-activated, but frankly I’m worried about doing that and them coming after the rest. Starting to look like Amazon is not going to be a viable venture for me if they are going to do this on a regular basis.
Is there anyone out there who can help advise on this please?


#3

I’ve had this for approx. 60 novelty jewellery products. Looks like i will have to lose the listings as no way of providing safety certificates for them all. I would be interested to know if this counts against you in your metrics as Amazon make no mention of that?


#4

In my experience of something similar happening to me before on Amazon, just because they have only started with 4 items, it doesn’t mean they aren’t about to flag your entire shop. Really it seems (see other people who have had 60 items flagged) that if it’s metal, it’s going to get flagged.

I’m seeing that unless Amazon are willing to exclude jewellery from their REACH requirement, that there will be no place for handmade jewellery sellers on Amazon any longer.

At some point soon, they will realise the issue with Handmade, it would help it along if we contact them directly at support to bring the issue to their attention.


#5

I’ve literally just had this too. Has anyone posted in the main Amazon forum about this? The items of mine they’ve so far highlighted are stainless steel (I think one item also had crystals that have a silver plated surround on it).

I don’t know whether they’re looking for statements from who I buy my parts from with regards the metals or what.


#6

Amazon is only concerned with Annex XVII n. 23, 27 and 63 of the REACH Regulation sets specific restrictions on the maximum allowable content of cadmium, nickel and lead

Amazon accepts two types of compliance documentation to approve or reinstate your ASIN:

(1) Declaration of REACH conformity

(2) REACH heavy metals testing reports

Personally I would send the self declaration, below is an example I drew up earlier, but there are plenty of templates on Google.

Summary

REACH Certificate of Compliance is a document certifying that a product is compliant with the EU REACH regulation (EC) No 1907/2006. It can be a testing report or statement issued by a third-party testing organization. It could also be a self-declaration


#7

Can you post back to let us know whether you are successful or not with this self-declaration. I’m in a FB group for others that sell under the handmade section and a number of them have just received the same email, so there’s quite a few of us trying to figure out the best way of dealing with this.


#8

Aha so we can Self Declare.

They’ve not made it fully clear now to self declare, by just emailing them and declaring it in the email?


#9

This is new so it will be trial and error as to what Amazon will accept.
Definitely still press suppliers and manufacturers for the relevant certification and of course only self-certify if you (as the “manufacturer” Brand owner/importer) are 100% sure your products are within the accepted levels required.
QUOTE <<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.>>
https://sellercentral-europe.amazon.com/gp/help/help.html?itemID=9MJWDA8TTMZFAXE


#10

Hi again, thanks so much for your reply and information regarding the Self Certification certificate. I’m going to think on this for a few hours and then decide best way forward. If I decide to go with the self declaration I will definitely report back how it went. But tbh I don’t feel I have the energy to have a showdown and unhelpful replies from an assorted array of robots. There isn’t much stock so it would be easier just to have it returned and focus on getting certification for all of the other products.
I know this is not tackling it head on but unfortunately this current load of nonsense has come straight on top of finding my carefully crafted (and branded via Intellectual Property Office) handmade items on a variety of other sites, bogus and straight, all of the information and photos having been lifted directly from Amazon - they’re not interested in that either. But that of course is another story…Thank you again for your reply… I appreciate you took the time and trouble.


#11

I’m thinking self declaration may well be the way forward for many sellers. Just like the letter of authorisation, where sellers authorise themselves on their own selling account, or the self invoicing. :slightly_smiling_face:
Amazon need to be seen to be following the rules and regulations and I’m hoping this will also tick all the boxes.
Please update the forum if pos, then together the forum can help guide and advise others, if / when they receive the same notification.


#12

I am just updating all my listings. Glad this happened early will take the handmade and other jewellery to another site. To silly by half lately. I cannot list today due to the dreaded sorry for the inconvenience try again later message. I just list elsewhere less hassle and more sanity


#13

Your comments are very useful but will Amazon accept a self declaration, I emailed seller support yesterday about the ASIN concerned and the notification we recieved but they said to us that there was nothing in their system about these emails.

I really hope that we are permitted to issue a self declaration, thank you for your help


#14

We have had it too one half dozen handmade rope rings? We can prove anything one them? So I had to delete the listings.


#15

I received 8 emails with anyting from one item to sixteen on for testing (around 45 items in total.

I upcycle watch movements, some up to 100 years old. Getting each of the various metals tested would push the prices way out of the means of my customers.

I thought at first that it was items that touch the skin, but they have included some of my brooches too.


#16

Good morning Anglozone and other sellers, Thought about it then I decided my first action, rather would be to contact Handmade seller support requesting advice from them whilst also pointing out that if there is a requirement for us artisans to “metal test” all fastenings it will be unviable to continue selling handmade jewellery on Amazon as this impacts the vast majority of Jewellery Artisans.
I have pointed out that I am perfectly aware of these regulations and buy from British suppliers, one of whom does have a Reach statement, but not all.
I’ve asked for help in clarifying exactly what handmade sellers are supposed to do to comply with this and continue using Amazon as a market place. I’ll report back when I have a reply.


#17

I currently have over 300 handmade jewellery items listed, each one has parts from multiple suppliers and upcycled parts up to 100 years old.

I will never be able to get cirtification to cover them all, so may just end up moving it all to another site.


#18

I have had 110 products flagged from around 500 - so I expect the others will be flagged eventually. I am not in handmade, but use small suppliers who don’t have a ready made Reach Certificate of any kind. So far this is only affecting two main suppliers, one has assured me there is no Cadmium, Nickel or Lead content, but is looking to get me "a declaration of its chemical makeup and kitemark from my pewter supplier "

Once I have this information I am not sure how to proceed. Do I email Amazon each individual ASIN (70 or so in total for this one supplier) and then hope 70 possibly different Amazon employees permit the listings or do I bulk send one email with all 70 asins on and hope some one accepts all the information provided and allows the listings to continue.


#19

I can see that is what I may have to do, happily I am on another very popular site but was really keen on the FBA aspect here as it creates more time for me to design and make. But let’s just see. I cannot believe there aren’t any exclusions or minimal requirements for very small sellers, there are with most EU directives. I’ll report back on anything I find out so keep checking in…


#20

I’m hoping to get a certification from my UK bullion supplier, and have emailed them.

However this platform has never performed particularly well for me compared to other selling platform, and the return rate is higher than other platforms also, well I barely ever get returns on other platforms, whereas they seem to be on the increase here.

If the return rate continues as it has been lately, I will also thinking it might be more worthwhile to invest more time and energy into other platforms anyway.