Reach Testing for Jewellery Sellers


with the self declaration.
Amazon did not accept my self-declaration. They simply moved the goalposts and said I must provide certification.

I am currently researching and so far, it appears to me, on reading through REACH (yawn) that jewellery is considered to be an ARTICLE and not a preparation or substance. ARTICLES are not required to be certified by REACH, according to Article 33 of REACH for jewellery.

I am going to send this to Amazon tomorrow.


What’s more they got the norms wrong. The Nickel Directive clearly states:

-0.2 µg/cm2/week for post assemblies which are inserted into pierced ears and other pierced parts of the human body
-0.5 µg/cm2/week for other products intended to come into direct and prolonged contact with the skin.


And they want ALL jewellery, even bracelets to fit under 0.2 µg limit… They are clearly wrong here. Also they do not accept self-declaration letters without ASINs which are not used outside of Amazon. The whole process clearly does not work as it should. Every handmade manufacturer who buys components from a supplier should be allowed to self-certify based on his knowledge obtained from the supplier.

As for the jewellery being an article so it doesn’t need to be reach compliant I don’t think it’s true. The Nickel directive clearly states that it’s regulating jewellery items and items that are in contact with the skin.


Having read the REACH documentation that states aluminium isn’t needed to be tested the problem is that Amazon has changed their own policies. Having argued the point with them several times I had this, this morning
" We do require testing aluminum and aluminum based alloys. Only in case of non-metallic jewelry, true vintage jewelry or precious metals silver, gold or platinum we do not require it. That’s Amazon’s policy towards metallic jewelry at the moment."

And they are insistent that the ASINs are within the documentation.

Still cannot believe that all that chinese cr*p available on marketplace has REACH testing with their ASINs attached.

I cannot provide such documentation so assume I will be shut down - hey ho!


Amazon have it wrong over this.
I went into REACH in great detail when setting up & contacted suppliers to seek testing certification. You do not have to register an article, or composite metals, if you import or manufacture < 1 MTonne of that constituent metal per annum. Otherwise products are exempt from the Regs.

Joke btw re Amz saying 925 Sterling Silver is exempt but it’s copper they’re concerned about as SS is a pure metal. Pure silver would bend in your hand…SS is 92.5% silver & 7.5% copper - that’s why it’s called 925!


Has anyone had their REACH documents from suppliers denied?

I’ve sent them the REACH docs from cooksongold site and the doc my alu supplier got from her manufacturer and they’ve stated neither are compliant.

After at least 4 generic please supply REACH documentation emails when they’d been sent and me asking why they’re not being accepted all I got was ‘these doucments are not compliant’.

I really don’t know what else to do?!


Yes, I also sent them Cookson Gold REACH statements for metal used in my manufacturing of products and they aren’t happy with them because they want the ASINS within the document.

Of course Cookson Gold will not be doing that for everyone who buys metal from them, and so it means that Amazon will be shutting down my products, and I will focus more on my other sales platforms.

I don’t think there is anything else left to do, I gave up weeks ago.


You’re quite right about silver. So either Amazon are paying lip service to REACH to prove to them how seriously they take the standards, and will just shut down a few token product listings, or if really meaning business they will eventually shut down half of their entire storefront and become a much smaller marketplace.

I can’t actually imagine them doing that if they think they can weasel out of doing it.

What is intriguing is as to why eBay isn’t doing this, or Etsy, etc etc, implies to me that it’s not a legal requirement at all, just something Amazon has decided on, without realising how impossible it is for half of their sellers. Now they’re probably sitting there wondering what to do about the mess they started.


What I don’t understand is, if that is the case ( and I think it’s because the ASINs aren’t in my docs) why not tell me that on Tuesday? Why keep just sending me the ‘send your compliant docs to…’ emails when all it took was a one sentence PERSONAL email advising me why my docs weren’t compliant! I too will now give up - I can’t be doing with the stress it’s causing every time an email drops for some products that haven’t even ever sold on Handmade!


yes I have had a few denied, same thing, copy and paste responses, without decent explanation. what amazon dont get is that i need to be going back to suppliers every time they refuse a declaration to ask them to try something different, and of course I cant tell my suppliers what they actually want so its all hit and hope guesswork.

I wonder how long it will be before my supplier tells me to get lost (or words to that effect)


I just cannot understand why they did not get us to sign a declaration stating our items are free of the offending substances and then direct any complaint to us to do deal with ourselves or via the product liability part of our business insurance. I suspect ebay and etsy if pushed will get us to sign such a declaration.


Cookson Gold are already ignoring me now on the second request for something else. They sent me a nickel compliancy document in response to my REACH document request, but I need a copper compliancy document - I asked 3 weeks ago if I could get the copper compliancy document, but not heard back yet from them.


Amazon have now sent a message saying 1 of the 100 or so items I could not get Reach certification far have been removed and this is in fact true. Not sure what happens to the other 99 listings.

Also adding "We remind you that you are responsible for the products you list on the and for complying with our policies and all applicable law. You will not be penalised for the first-time removal of these listings. However, we prohibit re-listing of the Affected Product(s). "


Amazon have not removed any of the products they contacted me about, saying that they would be removed without the documentation they requested.

Maybe now they realise how impossible it is for everyone to provide a REACH compliancy document for their specific products using the ASINS (ie we cannot REACH test each of our completed products), they’ve decided to accept the documents that have been sent in from component suppliers showing that the sellers supplier does conform to REACH.

I sent in a document from my component supplier, showing that my supplier is reputable and adheres to REACH standards.


No Chance. They are just behind. All will be removed soon…


Two more removed this morning.


Well they’ll be destroying their entire business model, because that’s going to be a hella lot of products removed from their marketplace, that sellers just sell elsewhere.

Buyers will come to realise that they cannot get anything they want from Amazon, that the Amazon marketplace is limited in what it offers buyers … leading them to drift to other marketplaces and not rely on Amazon alone.


Mine are continuing to get removed daily at a slightly increased number each day, so usually around 2am, and last night 5 were removed.


This is a painfully slow process - they are managing to remove around 10-12 listings a week and taking the weekends off. So it’s going to take them 8 or 9 weeks at this rate to remove just 100 listings.


Yep, all denied. Multiple documents from multiple large well known global wholesalers. Another waste of time and effort.


Well yesterday they informed me they were removing an item of mine. Just one.

This item is an item that has never sold and not within the three items they originally asked for certification for. Interestingly enough, within the three items they originally asked me for certification for … contained the item that is my best seller on here.

Very interesting that Amazon have chosen to remove an non best selling item of mine, instead of the best selling item they originally flagged. Funny that they have not removed the items that they originally flagged.

I sense some lip service going on, because as I said from the start, I cannot imagine Amazon is about to remove a huge percentage of it’s product data base and in turn profits.