This post is by Leah McHugh, an ecommerce consultant for ecommerceChris.com. 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.
GS1 (Global Standards 1) supply companies with a company prefix, used in GTINs (Global Trade Item Numbers).
UPCs (Universal 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.
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?
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.