Amazon sets chemical and heavy metal restrictions regarding products sold on its platform. This guide is divided into two parts. The first part focuses on Amazon’s Restricted Substances Lists, which primarily concern Amazon’s restrictions for its private label brands.
The second part focuses on substances that Amazon restricts in several categories of products for all sellers, as well as regulations that include substance restrictions. You must also comply with those restrictions if you want to sell your product on Amazon.
Content Overview
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Formulated Products Restricted Substance List
Amazon created a Restricted Substance List as part of its Formulated Goods Chemicals Policy that contains substances Amazon aims to avoid including in its private label brands. These restrictions also apply to all suppliers of those product categories in the United States and Europe.
Product examples
Here are some examples of formulated products mentioned in the Restricted Substance List document:
- Baby products
- Cleaning products
- Personal care products
- Beauty products
Substance examples
The Restricted Substance List contains many restricted substances which are listed by their chemical classes. Here we list some examples.
| Chemical class | Substance examples |
| Antiseptic (AS) |
|
| Nonylphenol & NP ethoxylates (NP) |
|
| Formaldehyde donor preservative (FD) |
|
| Parabens (PB) |
|
| Miscellaneous (MISC) |
|
| Phthalates (PH) |
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| Mercury compounds (HG) |
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| Perfluorinated chemicals (PF) |
|
Apparel, Footwear, and Home Textiles Restricted Substances List
Amazon intends to comply with the Apparel and Footwear International RSL Management (AFIRM)’s Restricted Substance List regarding apparel and accessories, footwear, and home textile products in North America, Europe, and Japan.
In this case, Amazon only mentions its private-label brands. However, the substances on AFIRM’s Restricted Substance List are considered dangerous substances and are either already restricted by one or more regulations or may soon be restricted.
Thus, if you sell any listed products in the mentioned markets, you should ensure that they do not contain any restricted substance above the limits.
Product examples
Here are several examples of listed products:
- Apparel (e.g. jackets, underwear)
- Footwear (e.g. sandals, boots)
- Accessories (e.g. hats, belts)
- Equipment (e.g. leg guards, bicycles)
- Wearables (e.g. fitness trackers, wireless earbuds)
- Home textiles (e.g. towels, blankets)
Material examples
The Restricted Substances List also applies to materials. We list here several examples of covered materials:
- Natural fibers (e.g. wool, linen)
- Blended fibers (e.g. cotton-polyester, wool-nylon)
- Synthetic fibers (e.g. acrylic, polyamide)
- Synthetic coated fabrics (e.g. textiles with PU or PVC coatings)
- Natural leather and fur skin (e.g. bonded or recycled leather)
- Coatings and prints (e.g. printing techniques (heat transfers), coatings (PVC))
- Natural materials (e.g. horn, wood)
- Other materials (e.g. glass, ceramic)
- Polymers, plastics, foams, natural rubber and synthetic rubber (e.g. polyamide (PA), neoprene)
- Metal (e.g. brass, silver)
- Feathers and down (e.g. feathers, down)
- Glue (e.g. hot melt adhesive, epoxies)
Substances examples
The AFIRM’s Restricted Substance List contains many substances and their corresponding restrictions and potential uses. We list several examples in the table below.
| Restricted substance | Restriction | Potential use |
| Acetophenone | 50 ppm | EVA foam |
| Azodyes (e.g. Benzidine) | 20 ppm each | Dyeing textiles |
| BPA, BPS | 1 ppm for items intended for mouth contact
1000 ppm for other products |
Epoxy resins, receipt paper, leather synthetic tanning agents |
| Short-chain Chlorinated Paraffins (SCCPs) (C10-C13) | 1000 ppm | Softeners, flame retardants |
| Chlorophenols (e.g. pentachlorophenol (PCP) and its salts and esters) | 0.5 ppm each | Pesticides, mold killers, insecticide |
| Chlorinated benzenes and toluenes (e.g. 2,4-Dichlorotoluene) | 1 ppm | Dyeing polyester fibers |
| Dimethylfumarate (DMFu) | 0.1 ppm | Anti-mold agent |
| Flame retardants (e.g. Pentabromodiphenyl ether (PentaBDE)) | 10 ppm each | Flame retardant for apparel and footwear, but should no longer be used |
| Formaldehyde | 75 ppm for adults and children
16 ppm for babies |
Anti-shrinking agent in textiles |
| Cadmium | 0.1 ppm extractable
40 ppm total |
PVC stabilizer, paints, fertilizers, and biocides |
Food & Beverage Packaging Restricted Substances List
Amazon also features the Packaging Restricted Substance List under its Chemicals Policy. This list contains substances that the company aims to avoid intentionally adding to the packaging of its food and beverage products in North America.
Note that while Amazon does not mention other suppliers, the listed substances are hazardous, and are either already restricted by one or more regulations or may be restricted in the future.
Substance examples
Here are some examples of listed substances:
- Heavy metals (lead, cadmium, chromium IV, mercury)
- Arsenic
- PFAS
- Perchlorate
- Bisphenol compounds (BPA, BPB, BPF, BPS, Bisphenol A diglycidyl ether)
- Benzophenone
- Selected solvents (2-Ethoxyethanol, 2-Methoxyethanol, N-methyl-2-pyrrolidone, Toluene)
Bisphenol A (BPA)
Amazon US prohibits the listing of BPA-containing products that are regulated at the state or federal level. This includes children’s bottles, children’s cups, and some children’s care products.
Amazon EU and Amazon UK ban the listing of food-contact products that contain BPA.
Note that Amazon’s BPA policy regarding Bisphenol A is stricter than that of EU substance regulations – which only ban BPA for some products (e.g. some child care products) while allowing a certain concentration of the substance in other products. As such, you may need to instruct your supplier to ensure that the materials are entirely BPA-free.
Which products and materials may contain Bisphenol A?
Bisphenol A is used in the manufacturing of plastics. Thus, products that contain plastic components, or are entirely made of plastics, such as food contact products may contain BPA. Keep in mind that some non-plastic items may still contain BPA, such as coatings.
Here we provide some examples:
- Baby’s feeding bottles
- Plastic lunch boxes
- Tin cans
- Preservative films
- Children’s plastic toys
- Electronics components
- Catheters
- Tubing
- Dental materials
How can I make sure my product does not contain Bisphenol A?
If you are importing your products from overseas manufacturers, you shall prioritize the ones with a history of producing compliant products. For example, you should select manufacturers that can already provide test reports showing compliance with regulations restricting the amount of Bisphenol A. Preferably, such test reports should be valid for similar products or materials that you intend to sell.
Additionally, you should provide clear orders and instructions to the factory on applicable BPA-related regulations, so that the manufacturer is aware that you won’t accept products that contain Bisphenol A.
Product Regulations
Amazon also requires third-party sellers’ products to comply with applicable product compliance requirements in each respective marketplace. Sellers on Amazon.com must, for example, comply with US substance regulations. Meanwhile, sellers on Amazon.de must comply with European Union substance regulations, such as REACH.
This section covers regulations that set substance restrictions in the US and EU. As mentioned, none of these regulations are specific to Amazon, but still relevant to anyone planning to sell through their online marketplaces.
REACH (EU)
REACH regulates the use of certain chemical substances in consumer products, in the EU. Amazon requires third-party sellers to comply with REACH substance restrictions and other requirements. For example, the use of the following phthalates is restricted:
- DEHP content < 0.1% by weight
- DBP content < 0.1% by weight
- BBP content < 0.1% by weight
- DIBP content < 0.1% by weight
Or, as another example, here are the restrictions that apply to some of the most common heavy metals:
- Lead content < 0.05% by weight
- Cadmium content < 0.01% by weight in plastic materials
- Nickel migration limit < 0.2 μg/cm2/week (for jewelry meant to pierce the human body)
Amazon may delist products of sellers that didn’t provide specific test reports showing compliance with REACH. As an example, for jewelry Amazon may require heavy metals test reports in compliance with REACH limitations.
In addition, Amazon may also require a declaration of REACH conformity or test reports drawn up by the manufacturer or a third-party lab testing company. The declaration should list all the substances contained in the product that are covered by the Substances of Very High Concern (SVHCs) list or Annex XVII.
Other EU Regulations
We list here some EU regulations that set substance restrictions:
- Persistent Organic Pollutants (POPs) Regulation
- Biocidal Products Regulation
- Cosmetic Products Regulation
- Plastic FCM Regulation
CPSIA (USA)
CPSIA applies to all children’s products manufactured, imported, or sold in the United States. This act concerns the safety of children’s products from the aspect of chemical element contents and migration rate, mechanical design, labeling, installation methods, and safety instructions.
CPSIA limits the content of phthalates in children’s toys or childcare articles, such as:
- DEHP content < 0.1% by weight
- DBP content < 0.1% by weight
- BBP content < 0.1% by weight
Also, CPSIA limits the content of other dangerous substances in children’s products. For instance, lead on paints and surface coatings should not exceed 0.009% by weight.
Further, compliance with applicable ASTM standards, such as ASTM F963, is also required. And some of these standards also set substance restrictions.
Amazon requires sellers of children’s products to submit test reports that demonstrate the compliance of the products. Such a test report should be issued by a CPSC-accredited third-party testing company. Additionally, Amazon requires a copy of the Children’s Product Certificate (CPC).
California Proposition 65 (USA)
California Proposition 65 is a state legislation enforced in California that restricts the use of dangerous substances in consumer products.
For example, food contact product sellers on Amazon should ensure their products do not exceed the MADL (Maximum Allowable Dose Level) set by California Proposition 65 on heavy metals or chemical substances:
- Bisphenol A < 3 µg/day
- Cadmium < 4.1µg/day
- Lead < 0.5 µg/day
- DBP < 8.7 µg/day
- DIDP < 2200 µg/day
- BBP < 1,200 µg/day (oral ingestion)
Also in this case, Amazon may require test reports and additional documentation at any time.
Other US Regulations
Here are some examples of US regulations that heavily focus on substance restrictions:
- Toxic Substances Control Act
- Federal Insecticide, Fungicide, and Rodenticide Act
- Federal Food, Drug, and Cosmetic Act
How does Amazon check 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 only when sellers list their products on the platform.
In some cases, sellers receive a document submission request long after the products have been initially listed, and are given a deadline to submit the requested documents. If the sellers fail to submit the required documents within the prescribed time, Amazon may start to delist the products – assuming the listing is not already suspended at the time of the document request.
