In 2018, Amazon released the Restricted Substances List (RSL) . This list applies to most Amazon private labels. Substances on the list are considered by Amazon to be carcinogenic, mutagenic, bioaccumulative, or due to other diseases that may be harmful to human health.
The following are some examples of substances included in the restricted substances list:
Bisphenol A (BPA) Phthalates (Plasticizer) Formaldehyde (Toluene) Parabens (Preservatives)
Currently, Amazon's list of restricted substances contains 11 phthalates, 12 formaldehyde-donating preservatives, and 8 parabens.
Amazon's initiative aims to improve the safety of its products by reducing the use of chemicals and build the reputation of Amazon's private label. It also encourages manufacturers to replace potentially hazardous substances with safer and non-toxic chemicals as defined in the U.S. EPA's Safer Choice Safer Chemicals Ingredients List.
RSL mainly affects baby products, household cleaning products, personal care products and cosmetics listed on the Amazon platform. Amazon said they will regularly update the RSL to include more substances and consider gradually applying the RSL to other categories of products.
Here we list some examples of products covered by Amazon RSL:
Shampoo, Lotion, Wipes, Detergent, Bathroom Cleaner, Sanitizer, Moisturizer, Lipstick, Powder, Eyeshadow >
Bisphenol A (BPA)
Amazon prohibits products containing bisphenol A (BPA) from being sold on its US site. Amazon Europe (e.g. UK , Germany , France and Italy) prohibits the use of Bisphenol A (BPA) in food contact materials and baby products. The following are examples of products covered by the ban:
cutlery lunch box baby pacifier baby bottle
It's worth noting that Amazon's BPA policy is stricter than the US and EU BPA regulations, which only prohibit BPA in certain products, while allowing products to contain certain (albeit lower) concentrations of BPA. Therefore, if you are an Amazon seller, you may need to inform your suppliers before the start of the production cycle and ensure that the production materials are completely BPA free.
Why does Amazon ban BPA?
Some scientific studies believe that human exposure to BPA will lead to hormonal disorders, brain decline and reproductive organ failure. As a result, the FDA in the United States and some agencies in the European Union (including the European Chemicals Agency ECHA) have banned or restricted the use of BPA in products.
Several U.S. states, including New York, California, the District of Columbia, Washington, Minnesota, and Connecticut, have implemented intrastate regulations, primarily covering food contact products and thermal paper for children. The latter can pose certain health risks to the fetus.
Amazon's US site lists any product containing BPA as a "dangerous good" and has banned the sale and trade of these products on its US marketplace.
Currently, Amazon Europe only bans some products that contain BPA, such as food contact materials and baby products. The relatively lax BPA policy on Amazon's European site may be due to the fact that the European Union has imposed relatively strict BPA content regulations on all products containing BPA . Therefore, they may think that when it comes to BPA for products within the EU, the corresponding BPA regulations should come into force automatically.
But one of the key principles of Amazon's product regulations is that all products sold on its site comply with applicable substance regulations at the country level.
Which products and materials may contain BPA?
BPA can be used to make polycarbonate, epoxy and other plastics. Therefore, products that contain plastic components or are made entirely of plastic, such as food contact products, toys, electronics, and medical devices, may contain BPA. But some non-plastic items can also contain BPA, such as the paint that covers products.
We provide some examples here:
Baby Bottle Plastic Lunch Box Tin Can Plastic Wrap Children's Plastic Toys Electronic Components Catheters Plastic Tubes Dental Materials
How can I be sure my product is BPA free?
If importing products from an overseas manufacturer, the importer should consider whether the manufacturer's previous production of products complies with relevant country regulations. For example, you can choose a manufacturer that can provide valid test reports showing compliance with the regulations of the product/material in compliance with the relevant BPA.
In addition, you should instruct the factory on the relevant BPA regulations and make it clear to the factory that products must be manufactured to comply with the relevant BPA regulations.
Finally, if you want to ensure product BPA compliance, you should contact a third-party laboratory testing company and have the product tested.
Amazon also requires products from third-party sellers to comply with all applicable product compliance requirements in each marketplace. For example, sellers on Amazon's US site must comply with US substance regulations. Sellers on the Amazon Germany site must comply with EU substance regulations such as REACH.
The following sections cover BPA regulations in the US and EU. As mentioned, none of these regulations are specific to Amazon, but are still relevant to anyone planning to sell through its online marketplace.
REACH (EU) EU
REACH regulates the use of certain chemical substances in consumer products. Amazon requires third-party sellers to comply with specific REACH substance restrictions and other requirements.For example, the use of the following phthalates (Phthalate) (plasticizers) is restricted
DEHP<0.1% (by weight) DBP<0.1% (by weight) BBP<0.1% (by weight) DIBP<0.1% (by weight)
Other heavy metal restrictions include:
Cadmium content <0.01% (by weight) Lead content <0.05% (by weight) Nickel migration limit <0.2μg/cm2/week
Recently, Amazon has begun to remove the failure to provide qualified REACH product test reports. For example, for jewelry products, Amazon may require a test report that meets the above REACH heavy metal content limit .
In addition, Amazon may also require sellers to provide a REACH compliance statement report drafted by the manufacturer or a third-party laboratory testing company. Substances covered in the REACH Substances of Very High Concern (SVHC) list contained in the product should be listed in the declaration report.
CPSIA applies to all children's products manufactured, imported or sold in the United States. The Act mainly deals with the chemical element content and migration rate, mechanical design, labeling, installation methods and safety instructions of children's products.
CPSIA restricts the content of phthalates (plasticizers) in children's toys or toddler products, such as children's toys
DEHP content < 0.1% (by weight) DBP content < 0.1% (by weight) BBP content < 0.1% (by weight)
In addition, CPSIA also limits the content of other toxic substances such as lead in products:
Total lead content on accessible parts < 0.1% (by weight) Lead in paints and surface coatings < 0.09% (by weight)
CPSIA also specifies that products need to comply with applicable ASTM standards, such as F963.
Amazon requires sellers of children's products to submit test reports to demonstrate product compliance. Such test reports should be issued by a CPSC accredited third party testing company. In addition, Amazon also requires sellers to provide a Children's Product Certificate (CPC).
California Proposition 65 (US)
California Proposition 65 is state legislation enforced in California that restricts the use of hazardous substances in consumer products.
For example, food contact product sellers on Amazon should ensure that their products do not exceed the MADL (Maximum Allowable Dose Level) set by California Proposition 65 for heavy metals or chemicals:
BPA < 3 mg/day Cadmium < 4.1 ug/day Lead < 0.5 ug/day DBP < 8.7 ug/day DIDP < 2200 ug/day BBP < 1200 ug/day (oral)
Note that MADLs for different substances may vary by product. In this case, Amazon may require sellers to provide test reports and other compliance documents at any time.
How does Amazon check for chemical compliance?
Amazon may require sellers to submit documents such as test reports, declarations of conformity, and other relevant compliance documents. Note that Amazon may request such documents at any time, not just when sellers list their products on the platform.
In some cases, sellers did not receive a document submission request from Amazon until long after the product was initially on the shelves, and were required to submit the requested documents within the deadline. If the seller fails to submit the required documents within the allotted time, Amazon may take the product off the shelf.
Amazon and compliance checks
Amazon usually requires sellers to provide the following information when conducting compliance checks on products:
One, the reason the product was removed from the shelves (e.g. Amazon implemented new requirements)
Two, what steps the seller will take to get the product back on the shelf (for example, sending a test report or image of the product label)
3. Amazon Email Address
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