Reach Testing for Jewellery Sellers


#202

I think this is because the cases are being dealt with by various SS operators - some are accepting the documents, some not. When this happened to me I uploaded the document again with an image of the accepted product alongside the one that was rejected (same style of product) - then they were accepted. If you are unable to upload your document under the ‘Performance’ section then upload a PDF with your actual case - they don’t like it, but keep reiterating that there is no where else to upload it and eventually you’ll get an agent that understands!


#203

Yeah I’ve tried sending the PDFs straight to the case, still get the same response to submit. Told them “it’s literally there in this thread if you scroll down” but they send the same reply again :laughing:


#204

I had this same thing when I got asked to do some last year. Same self-certification document set up, just stated different ASIN numbers - some went through the first time, some rejected. Last year they did seem to be better about giving some indication as to what “they thought” was missing. Some of the “missing” stuff was because the person looking at it didn’t read it properly. So I would point out where the “missing” information was stated in the document I sent them, which made some of them go through. There were 2 ASINs that I couldn’t get approved, didn’t matter pointing out that the information was included, the people (they were different people) just wouldn’t accept and approve them. So whilst they should all be working from the same hymn sheet so to speak, doing the exact same thing will get some approved and some not.

I wish you luck. I thought last year was bad, but reading about not being even able to submit the documentation in the first place, goodness knows what people are supposed to do…:thinking:


#205

If you design and make your own jewellery then you can self-certify. So if you buy 10 x components for making a piece of jewellery from 4 x different suppliers, you just need to ask them for their REACH declaration statement, once you are confident the components you are using are kosher and REACH compliant then you can self-certify your own designs.

So you want to really take a belt & braces approach when submitting self-cert REACH Declaration to Amazon to ensure they are accepted. Make sure you have the ASIN number within the REACH document AND a product picture also, and provide a separate REACH declaration statement for each affected ASIN.

To accompany the REACH statement have an introductory page, on headed paper with your own logo and business info (you can easily make your own on a word document). State that you are a UK designer and manufacturer of your own jewellery products which are sold under your own brand name. Also state other relevant info eg. if you have a trademark, if so gave the trademark number, and if a member of Amazon brand registry etc. Then state that you are the maker of product with ASIN no:xxxxxxxxxx.

Another very useful thing to do which will lend credence to your case, is to open an account with GS1 UK, they supply barcodes /GTIN-13 numbers, and just register each affected ASIN. It is really easy and simple to do, it’s a subscription based service, so you pay a yearly/monthly subscription depending on how many barcodes you want (for a thousand its around £140 per year I think). Once signed up, you just enter the product info for each product, only takes a minute or two for each one. Once the ASIN / product is regisered you will have a unique GTIN-13 barcode number to quote on your product your intro page to accompany your REACH statement.

It’s also very important that your REACH Declaration statement is signed, dated, and states your postion within the business (if any of these are missing they won’t accept it).

Once these 2 x pages have been drafted, you only need change the ASIN number & product pic (where appropriate GTIN-13 / barcode number), on each page to tailor to each affected ASIN / product.

Best of luck.


#207

@Purple_Wyvern_Jewels Yes I think it’s exactly like that! Today I sent in three products, same item different stones. Two were approved straight away, one is under review… :thinking:


#208

Hi folks, thanks for sharing such great thinking here. Feel free to send me elsewhere if I’m in the wrong place / the enemy, as my products are not handmade, they are made by a (great and responsible) factory in China. I am stuck in similar loops to you guys above - docs rejected and Seller Support just saying I need to submit docs, and I think I’ve already covered all bases.

If anyone is willing to critique my submission that would be super welcome! Context:
My company is a UK company
Brand registered
Unique designs (with EU design registrations)
Manufacturer is in China
They have done REACH compliance for products made in the exact same way, but not on my products
Of the two options (self declaration vs REACH certificate) I went with self declaration, but included the certificate for the products made in the same way in an appendix.

Here’s what I submitted, with blurring of specific stuff, but if anything rings out as wrong I’d love to hear. Below the images I quote what I wrote to Seller Support (to no effect).

I will go through point by point.

This is what you requested:

——

Declaration of REACH Conformity OR REACH heavy metals test reports
We require you to submit one of the following documents:

  • Declaration of REACH conformity 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.
    OR
  • REACH heavy metals testing report that show compliance with REACH’s heavy metals thresholds for all components of your product (see further details in the help page)

—-

I submitted a Declaration of REACH conformity.

Further to this I detail your requests and what is in my response:

—-

If you submit the Declaration of REACH Conformity, it should comply with the following requirements:

Request: - Must address any Substances of Very High Concern (SVHCs) contained in the product
Response: On page 1 the manufacturer has stated ‘There are no Substances of Very High Concern (SVHCs) contained in any of the products.’

Request: - Refer Annex XVII n. 23, 27 and 63
Response: On page 1 the manufacturer has stated ‘In reference to Annex XVII n. 23, 27and 63 of the REACH Regulation, all products do not exceed thresholds for Cadmium, Lead, or Nickel. This is supported in Appendix B which is a REACH heavy metals testing report for other products we manufacture in the exact same way’

Request: - Identify the product of the declaration (identification of jewelry product allowing traceability; it may be ASIN, FNSKUs, MSKUs or color image of sufficient clarity where necessary)
Response: On page 1 the manufacturer has stated ‘The products that this declarations refers to are included in Appendix A.’ Appendix A includes images and and ASINs of all SKUs.

Request: - Include signature, name and position of the person, who signed the document, and date
Response: The signature, name, position, and date of the person at the manufacturer are included.

As best as I can understand all requirements have been met.

In follow up dialogue you have said the following:

In order to sell Jewelry on Amazon, you must first submit the following:

  1. Declaration of REACH conformity (Certified by manufacturer or issued to the manufacturer by third party testing organization) containing:

• Name and Address of the Manufacturer/Importer from whom the Declaration of REACH Conformity was sourced.

The declaration is page 1. Name of the manufacturer is on page 1. Address is on page 6

As I understand it I have therefore completed all requirements. Please can you explain to me what more I can do?

Thanks!


#209

Have messaged you @La_Menagerie Hope you can get it sorted!


#210

I got all of my ASINs approved by Amazon with self declaration form. There is no secret here, your form must includes all information Amazon requires. As long as you do what they tell you to do, you’ll save huge amount of money for testing service.


#211

Was your self declaration something the same as this Haquil?


#212

It’s a similar form but I made a few changes. The form should be declared just for only 1 specific product with ASIN and an colored image of that product. The form must have your company address as well.


#213

I found amazon accept multiple ASINs on one document saving a lot of time- as long as you upload the document for each asin case separately (make sure you list ASINs with product images next to them and ensure to refer to the page the corresponding image is for each ASIN when uploading each). I did 40 on one and had no problems.


#214

An update from my end. As mentioned I have unique designs made for me by a company in China. I got the declaration written from them. This got rejected. I had another go where I said I was the sole importer in the UK / EU of these products and that I declare them compliant on behalf of my company (as opposed to the factory) - that worked! So that might be a thing to consider. Good luck


#216

Hello
Is someone able to post the original Amazon email without personal information. I received mine some months back and responded saying that we were flagged in error, but a couple of our ASINs have been removed so maybe I missed to respond to a couple of the ASINs. However I cant find the original link that took me to the page where I can submit the appeals. Does anyone have that please?
Thanks!


#217

In Seller Central click “performance” then “account health” then to the bottom right of the page you will see “Product Compliance Requests.” Click “view all” and there you will have access to upload the information for each product concerned.


#218

Hello, what materials have you prepared to pass the review?


#219

Hello. May I ask those who have submitted the form pictured above, would this kind of self declaration on the finished item without an actual safety certificate from the manufacturer of the components be sufficient for Amazon? I am a handmade jewellery seller so my items contain different components that I have purchased from different suppliers, most of this type of component is manufactured in China. If I submit self certificates for each of my items stating that they are safe, do you know if they are likely to come back to me and ask for other documentation? Has anyone sucessfully challenged this product removal and had their listings reinstated?


#220

Hi

Yes, you can self-certify in this case as they are your own designs and you make and assemble the product which makes you the manufacturer. It’s no different than a car maker, they design and make cars assembled but components are sourced from multiple different suppliers.

We make and sell our own jewellery designs also and have had our REACH self declarations accepted without any issues. Subsequently as with other sellers, they are now removing products without prior notice which is a lot more hassle.

In any case, you need to check with your suppliers first that the components you are using are REACH compliant, most bigger supplier are and will have had various compemnts tested already.

Best of Luck.


#221

I used this form for 4 bracelets I make myself that they removed - I get the components from two suppliers. I sent it to SS last Sunday afternoon and just now the 4 items are active and back in my inventory. No communication from SS to say that they have been relisted though, I just checked in manage inventory.

So yes you can self-declare using that form for the finished article.


#222

Dear Mike, thank you- so I do still need to check with my various suppliers first then? Do they have to provide something before I can do the self declaration? The issue I have is that I use many different suppliers and some are located in China…the supplies I buy state that they are nickel, lead and cadmium free on the listing, but no actual proof comes with that when I buy, I am not sure how to proceed …Selena


#223

Dear Penelope, thanks for your reply. May I ask, did you also contact your components suppliers first to get some kind of proof from them? Thanks, Selena