UPDATE January 2018: This second edition has been fully reviewed and revised.
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.
In 2016, 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. 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 over 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 seven to 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.
To be clear, resold barcodes aren’t illegal. 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 you are not breaking the law by using them. However, you are breaking Amazon policy if you use these codes on Amazon.
If you want to see who your UPCs belong to, you can check them on GS1’s Global Electronic Party Information Registry.
So far, Amazon’s enforcement of the UPC policy has been piecemeal. At this time it looks like they 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? You need to register with GS1 using your legal company name (or DBA for sole trader). You can then add brand information using GS1’s data hub.
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 or brand owner.
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. They 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. Amazon will assign your products a Global Catalog Identifier (GCID), which can be used in place of a UPC. You can find the requirement for applying for an exemption here (Seller Central login required).
If you’re creating bundles of your own private label products, use a unique GS1 UPC.
NOTE: The UPC must be unique to the bundle – you can not use a UPC from one of the items within the bundle.
For bundles of products from multiple brands, you can apply for a GTIN exemption (see above)
For bundles of products from the same brand, for which you are not the brand owner, you should request a UPC from the brand owner. Note: bundles with products from the same brand are considered as branded products. So, you could also request a UPC exemption with a support letter from the brand owner.
Listings with Incorrect Barcodes
What if I have existing listings with “bad” UPC codes?
I’m guessing that when you started out on Amazon, someone told you that 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 or merge your listing, and relist with the correct information.
Private labels: At this point, it looks like Amazon is targeting new listings and sellers listing other brands. 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.
I’ve asked around internally and have yet to get an answer on the right way (or Amazon sanctioned way) to handle this. So, as I see it, here are your options:
- 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 about whether the change is successful or not.
- The GTIN field is editable in Seller Central. I know Sellers that have changed this field on existing listings without issue, but I don’t know if that will be the case across the board.
- You could create a new, correct listing, and ask Catalog to merge it with the old listing.
Amazon is trying to clean up their catalog. 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 come with blocked listings and account suspension.
You decide whether it’s worth it.
This post was written by Leah McHugh, an ecommerce consultant for ecommerceChris.com.