EU REACH compliance: Heavy metals in articles

If you sell products on VegaVend, you must comply with all applicable EU and local laws and regulations, as well as VegaVend policies applicable to those products and product listings. To sell certain products on VegaVend, you are required to provide us with the declaration of REACH conformity or testing reports.

EU REACH regulation requirements

When listing products on VegaVend, you must 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 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:

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 adviser if you have questions about the laws and regulations concerning your product.

REACH compliance for products on VegaVend

To comply with applicable laws and regulations, VegaVend prohibits the sale of articles that exceed the restriction levels specified in Annex XVII. For certain products, VegaVend 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 VegaVend 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.

Listing jewellery on VegaVend

VegaVend’s policy requires all Vendors 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. The DOC document you provide must include all of the information listed below in a non-editable format, for example .pdf, .jpg, or.jpeg.

• Confirmation that the product confirms with Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH).
• List of Substances of Very High Concern (SVHCs) contained in the product.
• Name and address of the manufacturer/importer from whom the Declaration of REACH Conformity was sourced.
• Confirmation that the product conforms with REACH Annex XVII no. 23 (Cadmium), no. 27 (Nickel) and no. 63 (Lead).
• 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 VegaVend or a Market Surveillance Authority, we will require a REACH testing report.

All Vendors 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.

How to get compliance services

If you need help getting compliance certifications, testing and audits, use our network of VegaVend partners.

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 Vendor Dashboard, select the Account health tab.
2. Under Manage your compliance in the bottom-right corner, click on Product compliance requests.
3. To add compliance documents or appeal for a product, click Add/appeal compliance.
4. Provide compliance documents and information in the Provide documents section, or provide appeal information and documents in the Appeal request section.
5. Click on Submit for approval to send your submission for review by VegaVend.

If you are not able to locate the ASINs on Vendor Dashboard, contact Vendor Support for further guidance on this.

Your responsibility for providing documentation

If you are contacted, you are responsible for providing these documents to VegaVend. If you are the brand owner or importer, keep these documents on hand. If you are are Vendor, 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

Note: The information provided on this page does not, and is not intended to, constitute legal advice. All information, content and materials available on this site are for general informational purposes only.