Reach Testing for Jewellery Sellers


#21

I think my days of selling jewellery here are over too.


#22

Where do we find the “Seller/Vendor ID”? As this is requested to be submitted with the rest of the information they want.


#23

Ok, so here’s another angle. Just spoken to daughter (ex EU worker with contacts still). She says the vast majority of EU Legislation have exclusions for very small sellers. The problem is finding the exclusion amongst a mass of policy. These policies are not written for the likes of you or I… they are for the compliance officers of the major producers. She’s going to enquire as to where, ie which article, clause etc this exemption is, or indeed if it is present at all. With luck we may find an exclusion cause, which could justifiably work in our favour.
Anyway, will again keep you posted on this. Also it would be well worth all handmade sellers raising their concerns with Handmade customer services so they can see the strength of opinion and perhaps encourage them to pursue this more fervently. So pass this on …


#24

:wave:t3:Click on the link below.
https://sellercentral-europe.amazon.com/amazonStores/seller-stores/ref=xx_sbsc_dnav_xx

Checkout the URL. Your Seller ID is alphanumeric and starts with an A and is showing after merchantId=A************


#25

We also have many items flagged up by this. Will keep checking here to see if anyone is successful.

Thanks OP for starting this disucssion.


#26

OK, I’ve just received a reply. It didn’t answer any of my actual questions it was just a repeat of the Reach email sent yesterday which to be honest was what I was expecting… disappointing though. I’ve now created a removal order for the four items that were flagged. I can’t do a Reach test on them… simple as that. I’ve bought fastenings from reputable sellers but that’s all I can offer up. I’m sure at some point there will be more ASINS flagged but for now I have created a removal order for the 4 asins they believe are offending items. I’m still going to pursue that EU directive to see if it does actually apply to the small seller or if there is an exclusion.
If anyone goes the self certification route and is successful then please tell the forum. If I hear any more on the EU directive I will of course post it on the forum.


#27

All jewellery products produced containing sterling silver should be REACH tested for cadmium content compliance and is obligatory not voluntary under regulation EU 494/2011, which was issued on 2nd May 2011, and became enforceable from 10th December 2011. If your hand made silver items contain a minimum of 7.78 grams of silver metal it should be hallmarked anyway so REACH testing is done at the same time. If you haven’t been complying with this regulation you have been trading illegally for 8 years so disagree with your assumption that Amazon are being a little heavy handed…


#28

I have also had this email - when i go into my seller account there are no notifications requesting this info so I asked amazon support if the email was real or spam and they said they couldnt see anything about it on my account and asked me to report the email address to stop-spoofing@amazon.com .

Unfortunately i dont completely trust that Amazon support has provided the correct info but atleast i have proof that i have followed up to see if i needed to take action on the email.


#29

None of my jewellery items are over 7.78 grams and therefore I have no need to hallmark them. I’m a small seller working alone selling in small volumes - it would drive my prices up too high to hallmark every item made when the law does not require it.

I have been trading fully legally for 8 years and it’s rather presumptuous of you to assume and indeed insinuate that another business owner is falling foul of the law or does not understand business and trading law.

Your suggestion of 8 years also tells me you have visited my Etsy profile and made other presumptions based upon my start date there. I’ve only actually been selling jewellery for 3 years. I’ve been self employed for 19 years in total.

Watch your habit of making presumptions and instead work with facts by asking questions rather than making up things you think you know, but not in fact do not know.


#30

Hubbie thought the same - that it could be a phishing email but I have found the help document that is detailed by searching Seller Supports help. My concern is that Handmade support don’t have a clue about the emails going out, therefore how can they support us? It says contact Selling Partner Support (is that the usual customer support??) for advice but if they haven’t a clue…

It can only mean the end of jewellery on handmade as the costume jewellery suppliers that I’ve contacted either can’t or won’t provide documentation just a general my supplies comply…


#31

I contacted handmade seller support this morning asking questions. They replied by basically re sending the Reach information emailed yesterday regarding the 4 asins, I have since removed. (I know they are fine but cannot prove it). So I can’t think this is phishing… if it is then customer support is complicit.


#32

I have just had confirmation from Seller Support that the e-mail is not spam and was sent to “all the sellers for Jewelry product”.


#33

I didn’t presume anything I just stated what the legislation is, what it says and that you need to do to abide by it. Where is the presumption when you state quite clearly -

No presumption on my part, maybe reading what you write before making allegations would be a good idea on your part. I mentioned weight thresholds for hallmarking silver metal items as a method for you to get a REACH certificate cheaply, as it costs a quarter the price to hallmark an item as it does to apply for a REACH certificate and even less if applied in bulk.
Obviously, by your remarks, you aren’t interested in suggestions to cover your rear you just want a rant at the expense of anybody and everybody so although I have 20+ years experience in the jewellery trade and I am a member of the National Association of Goldsmiths I will stay out of it and leave to to your own devices.

Now who is presuming lol. I mentioned the date as that was when the legislation was passed and the later date when the legislation came into force. If you have only been producing silver jewellery for 3 years and during that period you haven’t been following the rules set down within the legislation then common sense tells you that you haven’t been trading legally for 3 years. It doesn’t matter how long you have been self employed only the regulations that you must follow to trade during the period you have been producing that product for the purpose of selling.


#34

Hallmarking is not really an alternative to a REACH certificate because all it does is to certify it is silver or gold, not that it does not contain nickel, cadmium or lead.

I got quite a shock when I called Sheffield Analytical Services, part of the Sheffield Assay Office, to get some idea of the cost of an analytical report regarding presence of nickel, cadmium & lead. It all depends on the number of components. For instance a pendant which is all in one piece it is about £65. However a silver pendant of 2 or 3 components (like a bale etc) together with a silver chain which also has various components, it will set you back some £150 and takes 2 weeks.


#35

Have any of you had any responses to the self-certification you sent amazon last week? Or any responses at all?


#36

We have had about 35 ASINs affected. About 75% of that list are not even jewellery items. I tested the process outlined in our email on one which was a jewellers saw frame and saw blade set - advised as its not jewellery or imitation jewellery worn next to skin - it should not be applicable to this ruling. The response I got back was a standard “We understand that you are having issues with listing. Certain brands and categories require approval to be sold on Amazon, and some rules may change throughout the year.”

So no use whatsover so far


#37

Contact the bullion dealer that you purchased the metal from before processing the metal into products. The regulations require all ‘substances’, which includes all metals, to be registered under REACH. It is important, however, to note that REACH Regulations distinguish between ‘substances’ and ‘preparations’ (which are covered by REACH) and ‘articles’ (which are not governed by REACH and do not require registration). So you are required to have a REACH certificate from the certain types of ingots such as ‘as cast’ ingots, rolling ingots etc which are classed as ‘preparations’ but not the end product which is classed as an article. If you can’t obtain a certificate from your original supplier then you need to gain registration for the metal prior to production. It is cheaper to get REACH registration when it is being hallmarked than it is separately. If you don’t get it registered when it is in its original supplied form or your supplier hasn’t had it registered and can issue you with a certificate of conformity or REACH code then you have no option other than to get the final product tested as a preparation rather than an article which is as you have found is prohibitively expensive. And people wonder why we voted for brexit when you come across complex regulations such as these courtesy of Brussels under the guise of cutting red tape.


#38

thanks for answering - think I’ll just send what I’ve drafted. 13/16 of those they detailed for me are 100% aluminium jewellery so no cadmium, nickle or lead but I imagine I’ll get the same response as you :wink:


#39

I’ve noticed that the three items they removed from sale, are now up for sale again, and so while they haven’t responded to my email, they seem to have accepted my self declaration.


#40

Did they actually take yours off sale then? I thought we had until the 8th to respond or they would take them off then. None of mine have disappeared. But thanks for the comments on self-certification. It only applies to 3 of mine at the moment but suppliers won’t give me or don’t have certification themselves. They’ve only given me their reassurances. Thanks for your input.