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 (that is, finished products) cannot be sold if they exceed limits for certain chemical substances, such as heavy metals. For more information about REACH, go to the ECHA 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	no 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	no 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 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 and show a reference to REACH Annex XVII n. 23, 27 and 63.

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. It must contain the following:

• Identification linking the declared object ASIN to the document: This can be an FNSKU, an MSKU or a colour image of sufficient clarity. For jewellery products, it must allow traceability.
• A signature and a full name of the person who signed the document.

(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 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; and no greater than 0.5 μg/cm²/week for jewellery intended to come into direct and prolonged contact with the skin	Declaration of REACH conformity, or Testing reports

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 Service Provider Network page.

How to submit information

If you receive a request from us for compliance documents, complete the following steps to submit the requested information:

1. In Seller Central, select the Performance tab and choose Account Health.
2. Under Manage your compliance in the bottom right corner, click Product Compliance Requests.
3. To add compliance or appeal for a single product, click Add/Appeal Compliance. To add compliance or appeal for multiple products, select each product on the left hand side of the product and click Action Selected Products at the top of the product requirement table to make a selection about how you would like to submit documents and information.
4. Provide compliance documents and information in the Provide Documents section, or provide appeal information and documents in the Appeal Request section.
5. Click Submit for Approval to send your submission for review by Amazon.

If you are not able to locate the ASINs on Seller Central, contact Selling Partner Support for further guidance on the same.

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.

Additional information

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

• Remove inventory overview
• Fix stranded inventory
• All EU National helpdesks for REACH Regulations
• European Chemicals Agency (ECHA)
• UK REACH page