EU REACH compliance: Heavy metals in articles

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. For more information about REACH, refer to this help page.

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 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 request approval or reinstatement of my ASIN?

If your ASIN is jewellery or imitation jewellery, as described above, or has been subject to a physical test and we require additional documentation, you will receive an email with more detailed instructions. In this case, if you want to sell or continue selling these products on Amazon, submit the following information to eu-chemical-safety@amazon.co.uk:

• Company name
• Seller/Vendor ID
• Email address
• Phone number
• The EU marketplaces where you want to continue listing your ASINs
• A list of ASINs you are applying to sell

To speed up the process, submit one application per family ASIN/variation/model number.

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

(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.

Table 1. Overview of thresholds and document types

Applicable regulation	Threshold	Type of document
REACH – Annex XVII 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.

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.

I don’t think my product should have been subject to a document check. Who should I contact?

Contact Selling Partner Support (SPS) for information about why your product was in scope of a document check. If you believe there has been a mistake, SPS can help to file your request to the relevant Amazon team.

Additional information

We strongly encourage you to visit the following sites for more information on REACH:

• All EU National helpdesks for REACH Regulations: https://echa.europa.eu/support/helpdesks
• European Chemicals Agency (ECHA): https://echa.europa.eu/regulations/reach/understanding-reach