SWTC SWC · Saudi Arabia

Amazon Sellers Asked to Supplement RSL Reports: Changes in 2026 Audit Criteria and How to Respond

## Background RSL (Restricted Substances List) is not a regulation, but a chemical restriction requirement set by brands or retailers themselves. On platforms such as Amazon and AliExpress, for categories without mandatory certification requirements (such as household goods, accessories, textiles, and pet supplies), platforms often require sellers to provide RSL test reports on the grounds of "product safety" or "brand compliance." Since 2026, frontline feedback shows that this type of spot check has shifted from "random" to "category-targeted," and more detailed review criteria have been imposed on report validity, item coverage, and sample consistency. ## Frontline Observations In the past three months, among seller inquiries received by Shuwang Testing and Certification Platform (https://www.shuwangtc.com), cases of RSL reports being returned by platforms were concentrated in four types of issues: 1. **Report items do not match platform requirements**: Sellers submitted RoHS or REACH-SVHC reports, but the platform required a specific brand's RSL list (such as Walmart RSL or Amazon's own restricted substances policy). Different retailers' lists vary in scope for items such as heavy metals, phthalates, azo dyes, and APEO, making "one report for all" increasingly difficult. 2. **The qualifications of the report issuing institution are not recognized**: Platforms have begun verifying whether the report issuer has CNAS/CMA or equivalent qualifications (such as ISO 17025 accreditation). Some reports provided by sellers came from unqualified laboratories and were directly judged invalid. 3. **Samples are inconsistent with the actual products sold**: The sample model, color, and material in the report do not match the listing description. Especially for products with multiple SKU variants, the platform will require each variant to provide a corresponding report or a coverage statement. 4. **Reports are expired or standard versions are too old**: RSL lists are usually updated annually, and platforms will check whether the standard version cited in the report is the currently valid version. Using a standard version from two years ago is likely to result in rejection. In terms of turnaround time, a complete RSL report (covering common platform items) has a reference range of 5–10 working days, and the reference cost range is RMB 1,000–5,000, depending on the number of test items and sample complexity. ## What Companies Should Do **Step 1: Confirm exactly which list the platform requires.** Do not guess. Check the performance notification or compliance requirements page in the seller backend to clarify whether it is the "Amazon Restricted Substances Policy" or a "specific brand RSL." The test items corresponding to different requirements differ greatly. **Step 2: Choose a qualified partner laboratory.** Shuwang Testing and Certification Platform does not engage in testing activities, but can assist sellers in matching with partner laboratories that have CNAS/CMA or ISO 17025 accreditation, and conduct a pre-review of the testing plan to ensure the items cover platform requirements. **Step 3: Prepare samples and materials by variant.** For variants with multiple colors and materials, confirm with the laboratory in advance whether coverage can be achieved through "worst-case samples" or whether variant-specific testing is required. Keep a clear correspondence between samples and listings. **Step 4: Establish a report ledger and track standard versions.** It is recommended to check the RSL list version quarterly and initiate updated testing 1–2 months before the report expires, to avoid delisting due to report issues before peak season. **Step 5: Align reports with supply chain information.** Ensure that the manufacturer and factory information in the report is consistent with the actual supplier. The platform may require purchase contracts or invoices as supporting evidence during review. ## Notes RSL reports are voluntary/platform-required compliance documents, not mandatory requirements under EU or U.S. federal regulations. Platform review criteria will be adjusted dynamically. The turnaround times and costs described in this article are public industry reference ranges, and actual results are subject to engineer assessment and laboratory scheduling. Testing is completed by partner laboratories, which issue the reports. Shuwang Testing and Certification Platform provides solution selection, testing coordination, and document pre-review services. **One-sentence conclusion**: In 2026, platform review of RSL reports has shifted from "whether it exists" to "whether it is correct." Sellers should select items according to the platform list, prepare samples by variant, manage ledgers by version, and incorporate RSL into routine compliance management rather than temporary remediation.

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