Amazon’s New UPC Policy: What it Means for Sellers

Amazon's New UPC Policy

This post is by Leah McHugh, an ecommerce consultant for For Amazon sellers, having their merchant account suspended means losing time and money trying to get back in business. ecommerceChris shows sellers how to keep their accounts healthy, or, if the worst should happen, how to get their account back from a suspension. This post is an extended version of Decoding Amazon’s New Barcode Policy, published on the ecommerceChris blog.

Earlier this year, Amazon quietly made a change to its Product UPC and GTINs policy (Seller Central login required). It now states:

We verify the authenticity of product UPCs by checking the GS1 database. UPCs that do not match the information provided by GS1 will be considered invalid. We recommend obtaining your UPCs directly from GS1 (and not from other third parties selling UPC licenses) to ensure the appropriate information is reflected in the GS1 database.

What does that mean for sellers?

Well, first you need to understand why Amazon has made this change. Right now, Amazon has millions of duplicate listings, where someone has slapped their own barcode onto an existing product in the catalog. Duplicate listings are not good for buyer experience. It confuses customers and dilutes product reviews.

The GS1 policy gives Amazon tighter control of what constitutes a valid listing and reduces the chance of duplicate listings. How? Let’s take a look at how barcodes work.

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Barcodes 101

GS1 (Global Standards 1) supply companies with a company prefix, used in GTINs (Global Trade Item Numbers).

UPCs (Unique Product Codes), EANs (European Article Numbers) and JANs (Japanese Article Numbers) are all different kinds of GTINs

GTINs are then turned into Barcodes which are a machine-readable code in the form of numbers and a pattern of parallel lines of varying widths.

The first 7-11 digits in a barcode, is a unique identifier known as a company prefix. The company prefix identifies the manufacturer or brand owner of the product. This is used to create UPCs for your products.

The ONLY place you can buy legitimate UPCs is through GS1.

The problem with buying UPCs from resellers is that they are selling you someone else’s (hopefully unused) code. The company prefix will not identify you, it will identify the original owner of the UPC. So, if you sell apparel and your code identifies a liquor company, that isn’t going to fly with Amazon anymore.

Resold barcodes aren’t illegal, per se. I consider UPCs obtained from any source other than GS1 to be grey market. As of 2002, GS1’s license agreement has stated:

The license agreement for our membership prohibits any use of the Company Prefix other than for the use of the owner company, including but not limited to selling, sharing, leasing, sub-dividing, or re-selling the Company Prefix.

Most resellers are selling codes obtained prior to 2002. So they are not breaking the law. However, you are breaking Amazon policy if you use these codes on Amazon.

Want to see who your UPCs belong to? You can check them on GS1’s Global Electronic Party Information Registry.

At this time it looks like Amazon are checking the manufacturer field, brand and title to match against GS1. Amazon has started:

  • Automatically checking UPCs against their list of Designated Brands Requiring UPCs when a new listing is being created.
  • Checking existing listings that cite a Designated Brand as the manufacturer, or mentions them in the title.
  • Checking UPCs manually when a seller is under investigation for other reasons, such as misuse of ASIN Variations.

What if your brand name is different from your company name, so it doesn’t match GS1? In this scenario, you would be compliant with policy. If it came to your listings being blocked because your DBA didn’t match your company name in GS1, you could very easily provide your DBA paperwork and GS1 certificate, proving your codes are legit.

Listing Branded Products That Aren’t Your Brand

If you’re listing a branded product, that is NOT your brand, then you should be using the barcode supplied by the manufacturer.

Amazon policy forbids adding your own UPC to someone else’s product. Your listing and likely your seller account will be shut down. You may even hear from the brand owner’s lawyers. Just don’t do it.

What if the products I’m reselling don’t have a barcode? Contact your supplier. There is no official publicly available list of barcodes, as there is no requirement for registering individual UPCs. Your best source is the manufacturer.

If the products do not have GTINs, you can apply for an exemption from Amazon’s UPC requirement. You need a letter from the brand owner confirming that their products do not have a GTIN as well as a link to the product website, or images of the products. You can apply for the exemption here (Seller Central login required).

Listing Your Own Private Label Products

You should ONLY be buying your UPCs from GS1. GS1 will assign you a company prefix, that will identify you as a brand owner. Any company can buy a prefix – you do not need to be incorporated.

May I buy cheap UPCs from eBay or another reseller? No. No, you may not. Go back and read Barcodes 101. If you buy UPCs from a reseller, the codes will identify someone else as the brand owner.

Should you ever decide to sell your products to major retailers, they will only accept GS1 issued UPCs with your company prefix.

May I list my private label products without a UPC? In certain categories, you can apply for an exemption through Amazon’s Brand Registry. Amazon will assign your products a Global Catalog Identifier (GCID), which can be used in place of a UPC. You can apply for the Brand Registry here (Seller Central login required).

What if I already have Brand Registry, and have been using bad UPC codes? If you have Brand Registry, then you do not need to list with a UPC. If you set your key attribute as UPC, then you should change your key attribute. Contact Seller Support and request support with Brand Registry. Ask them to change your key attribute to whatever you want to change it to. You should get a response from the Brand Registry team whether the change is successful or not.

Listing Bundles

Here’s where things get tricky. Product bundles require a unique UPC.

The safest option is to create bundles of your own private label products, and use a GS1 UPC.

The second option is to create bundles of products for which you are an authorized reseller. Ask the manufacturer of the products to supply a UPC for the bundle.

The least safe option is to bundle items of different brands, listing the bundle under your own private label, and your own GS1 issued UPC. This is the current loophole which some sellers are taking advantage of to create their own unique listings. I can see this practice coming under scrutiny as more and more sellers attempt to exploit it.

Listings with Incorrect Barcodes

I’m guessing that when you started out on Amazon, someone told you you could buy cheap UPCs from eBay. I still see this advice given regularly by so-called Amazon experts. So, chances are, you have existing listings with not-so-legit UPCs. Now what?

Resellers: is there already a listing with the correct information? List against that and shut down your listing with the incorrect UPC.

If there isn’t a correct listing, you should still shut down your listing, and relist with the correct information.

Private labels: At this point, it looks like Amazon are targeting sellers listing other brands, and new listings. However, Amazon’s wording is very clear that this policy applies to all UPCs:

All invalid product UPC listings will be removed and may result in your ASIN creation or selling privileges being temporarily or permanently removed.

It is only a matter of time before they begin cleaning up their entire catalog.

Your best option is to close your listings and create new, correct listings with GS1 UPCs. Yes, you will lose your reviews. Would you rather lose your seller account?

Leah McHugh
Leah McHugh

Summing Up

2016 is the year of catalog cleanup for Amazon. It’s in their interest and it’s in their customer’s interest to maintain the integrity of their product listings.

As a seller, you need to make sure your seller account is policy compliant. Weigh the expense of following the rules against the potential lost profits that comes with blocked listings and account suspension.

You decide whether it’s worth it.

31 comments on “Amazon’s New UPC Policy: What it Means for Sellers

  1. Great post Leah. Am I correct in assuming that one UPC must have only one listing on Amazon? If yes, is there any suggestion for listing products with fitment data such as printer ink, laptop batteries etc.?

    The issue here is that the better customer experience is to put the fitment data into the title and list one UPC multiple times with different titles e.g “HP Pavillion dv7-1000 battery”, “HP Pavillion dv7-2000 battery” etc.

    With the new UPC policy could we create multiple listings with different titles but the same UPC?

    When there

  2. We have thousands of UPC’s purchased from a third party. We use them to create our own bundles of mixed branded products. When we check the UPC’s for ownership information, the GS1 system responds that there is no record found for owner information (GS1 Japan). Since the results do not find any conflicting ownership information, I’m wondering if those bundles will be safe? We are also updating all of those bundles with our company name for the manufacturer and brand fields, and have removed brand names from the titles and created more generic titles.

    1. Without seeing the actual codes, I can only make an educated guess.

      If the company prefix does not come up in GEPIR ( GS1’s Company Database), then my guess is that they are not legitimate GTINs or they have expired. Either way, this would make them invalid.

      I would suggest contacting GS1 for further information.

  3. The big problem in the catagory of toys and toy manufactures is that the manufacturers use the same UPC code on many related items. An example would be in diecast cars where a manufactures list the same code for every color or for the same car that is stock and one that is custom. They also sometimes offer the same item with different UPC codes depending on the packaging or special promotion they have offered. The variations can differ greatly and using the manufactures UPC code on Amazon makes it difficult for a buyer to find what they are seaching for. I can understand Amazons thinking because their catalog is a mess. In the toy and toy collector catagory eBay is much easier to shop.

  4. I have seen nothing of this policy in the US. I cannot imagine it will fly very well with manufacturers or sellers in the US. Many manufacturers use recycled numbers – their own or others they have bought. The UPCs are unique to them but no longer match the GTIN database. It also would not be beneficial for consumers as it eliminates lots of bundled buying choices and eliminates a huge part of Amazon’s catalog. It will be interesting to see what happens.

  5. Can you explain this in more detail?

    “The least safe option is to bundle items of different brands, listing the bundle under your own private label, and your own GS1 issued UPC. This is the current loophole which some sellers are taking advantage of to create their own unique listings. I can see this practice coming under scrutiny as more and more sellers attempt to exploit it.”

    Why do you think that using different brands in a bundle is an issue or an exploit? For example, a S’More’s bundle. Marshmallows, Chocolate, and Graham Crackers. All 3 from different manufacturers. Amazon doesn’t even adhere to MAP…in fact they seem directly opposed to it as it’s not in the best interest for a buyer.

    Your article has some good information, however, this is not a policy that has been posted on Seller Central recently. Normally when there’s a new policy or feature (like the new repricer), it will show up on the Seller Central home page. I don’t believe this is a new policy, just one that’s being enforced. Amazon has 45 million books alone. “Fixing” their catalog will likely take years.

    1. I agree that a bundle like the one your described provides value to the consumer.
      The reason I think it will become an issue is because we are already seeing sellers exploit the bundle policy to create duplicate listings and to get around the UPC requirements for Designated Brands Requiring UPCs. For example, a branded item that has been put in a “special” box and then is listed under the sellers PL.

      1. Ah, I see what you mean I think. So a PL seller has a registered brand, but begins using their UPC codes for bundles, thus making them their own branded product even though it’s really just a pack of smores.

        One thing that seems monopolistic to me is that unused UPC’s can’t be sold to a third party and then registered with GS1. I suppose it would be an administrative nightmare. Still, they’re the only ones that can sell new UPC’s, thus artificially inflating the price beyond their real value.

  6. Hi Leah
    I started out with private label products last year on Amazon. I bought UPC codes from as that was what was recommended to me at the time. I registered my brand name with Amazon and have UPC as the key attribute.
    I have built up a lot of reviews on some of the products and it would be a shame to lose them all and start again, especially when newer competitors in the same categories are catching up with me review wise. But I know it would be worse to have my account shut down.
    You mentioned that key attribute could be changed. I never understood what the other options were… I don’t have part numbers printed on the packages or no manufacturer number, catalogue numbers etc. Could it be any name or number?
    Do you know if I have to have an official company registered in the USA to be able to get barcodes from GS1? I’m in Europe but only selling on at the moment.
    I’m happy to only sell on amazon and not in stores but for future products would only use GS1… but for now, to keep things moving, I want to try save my listings and reviews, and have UPC exemption.
    Thanks for the article and your help

    1. Thanks Norm,

      As you are already enrolled in Brand Registry, you could you the GCID which is a 16 character ID Amazon assigned to your listings. You can find it in your inventory report. You would need to contact the catalog and ask them to change your key attribute. The GCID can be used across countries.

      If you have no intention of selling in stores, then I wouldn’t bother using a UPC if you are able to use the exemption. But, if you choose to purchase from GS1, they have offices in most European countries, so you are able to register in the country where your business is located.

  7. Hi Leah,

    Is it not possible to purchase new UPC codes from GS1 and then just change the barcodes round on your existing listings rather than deleting the whole listing.

    Or will a change in barcode mean you loose all your data for that listing?


    1. Hi Abz,
      Unfortunately, it is not possible to change the UPC on an existing listing on Amazon. To change the UPC you need to create a new listing with the correct information and delete the incorrect listing.
      Alternatively, if it is your Private Label you can apply for Brand Registry and use something other than UPC as your key attribute. That would remove the incorrect UPC’s from your existing listings.

  8. UPDATE: Speedy Barcode has added the following verbiage to their site, addressing Amazon’s policy change:

    “Amazon has recently updated their company policy and put a barcode ownership verification process in place. At this time, Amazon is using GS1’s GEPIR database as the sole means of verification. We have contacted Amazon to let them know that the database they are using is not current and does not reflect correct ownership information for all of the barcode numbers GS1 has listed, but as per an email from them, they have no plans to change their process. At this time, you have no choice but to obtain barcodes from GS1 if you want to list your products on Amazon.”

    1. We dealt with Speedy Barcode in the past and they have no clue what they are talking about. Go straight to GS1 US.

  9. Hi Leah,

    When I’m setting up my company prefix on the GS1 website, do I put my importing LLC as the company name? Or do I put my brand name (very different from my LLC)? I read through their FAQ but couldn’t find the answer. Would prefer LLC, but trying to select the option that won’t get me flagged/suspended by Amazon later.

    Thanks for a great article by the way.

    1. Thank you, Billy.

      You must register with GS1 using your legal company name. And your should register a DBA for your brand name.

      If it came to your listings being blocked because your DBA didn’t match your company name in GS1, you could very easily provide your DBA paperwork and GS1 certificate, proving your codes are legit.

  10. What if your company is a sole proprietorship and has a DBA for the company name and the company name is different from the Brand? Should the UPC codes be registered under the company DBA, the sole proprietor’s name, or other?

  11. 1) We sell our private label product on amazon and we have brand registry for our brand. We have selected Manufacturer part number as unique identifier for all our listings which is different than UPC, However we also provided UPC code along with Manufacturer part #. But these UPC codes were not bought on GS1 website so GS1 does not have our company info for these UPC code.

    Now amazon changed the policy on us suddenly. Even though I have not received any complain from amazon about any of our listing, Is this policy update will affect our listing which is under our brand registry with unique manufacturer part # along with so called non complain UPC code.

    1. Hi Rina,

      This is a developing story. In the last few weeks we have seen Amazon merging listings with different UPCs. We have also seen Amazon changing Product IDs to ASIN in Seller Central.

      Brand Registry with a key attribute other than UPC is the best protection you can do on your own, other than closing and relisting the items with the correct information.

      Alternatively, you could contact catalog and ask them to change the listing information. I do not recommend changing the product IDs yourself.

  12. Hi,

    I sell a lot of vintage items (Corningware, Pyrex and dinnerware) that do not have UPCs. Many of the original manufacturers are no longer in business. The UPC requirement on Amazon has significantly impacted my small business. Most people are surprised when I tell them that selling vintage and collectible items on Amazon was more profitable for me than selling on eBay or other sites. It looks like I won’t be able to do business on Amazon for much longer. If I understand it correctly, I can’t use my own UPC on a 1970s Pyrex casserole, because I’m not the manufacturer. I still see many listings of vintage and collectible items, so I’m wondering how those sellers are bypassing the UPC requirements.

  13. Hi Leah,

    Great article, I’ve read it several times actually.
    I wanted to react in the comments and build on Rina’s comment as well. I’m in the same situation, that is that I’ve switched the key identifier from UPC to manufacture part number with brand registry; however the UPC, non registered under my PL name, is still shown in the listing. Is that still OK?

      1. Leah, another question I had was this:
        If I’m brand registered with manufacture part number as a key identifier, what should I use as barcodes when sending products to amazon’s warehouses? Should it be the manufacture part number (which in my case is sku number)

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