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Importing from Asia and selling on Amazon? That means you are fully responsible for ensuring that your product is fully compliant with all mandatory safety standards, labeling and document requirements.
Keep reading, and you will learn if your product category requires a pre-approval, and the documentation you must provide to Amazon’s category approval team to gain access.
In addition, we also explain why you cannot rely on your supplier to help you out, if something goes wrong – in which case your account may be suspended.
Who is responsible for ensuring compliance of products sold on Amazon.com?
The Seller is always responsible for ensuring that the product is compliant with all mandatory safety standards, labeling requirements and documentation requirements.
The supplier is not responsible, which means that it’s entirely up to you – as an importer and/or Amazon seller – to go through the compliance procedures.
For example, this may include the following steps:
1. Assess all applicable safety standards and chemical restrictions that apply in the target market, and communicate these to your supplier (before production)
2. Confirm all applicable labeling requirements, and create label files that you later send to the supplier (again, before production starts)
3. Follow up with lab tests, after production
4. Create all mandatory documents, such as photocopies and declaration of conformity
What you must do to comply in practical terms depend on the product and market.
Does Amazon develop their own standards?
No, Amazon.com doesn’t develop their own safety standards or other product standards. Instead, they only refer to the national standards in the target market.
Hence, a seller on Amazon.com must ensure compliance with safety standards and labeling requirements in the United States, while sellers on Amazon.de must comply with European Union regulations.
That said, Amazon.com has in the past required sellers to prove compliance with ‘voluntary’ standards. In the last case that I am aware of, they forced Hoverboard sellers to provide compliance with UL standards, which are not required by law.
Perhaps we will see more of this in the future.
Do compliance requirements apply to all product categories?
No product is completely outside the scope of regulation. For example, all products must be ‘safe, even if there is no specific standard that cover that product.
Further, general labeling requirements apply to basically all products. Hence, it can be said that all products are covered by national product regulations – even if the only requirement is a country of origin label.
As said, Amazon only (or at least for the most part) reflect national requirements.
That said, some products are deemed as more risky than others, meaning that they are subject to a stricter set of safety standards, document, labeling and third party lab testing requirements.
Hence, Amazon.com requires that you obtain a pre-approval from them, before listing products in certain categories. A list can be found here, with a few examples below:
- Beauty & cosmetics
- Shoes, Handbags & Sunglasses
- Shoes, Handbags & Sunglasses
For some categories, the process may only be a matter of a brief product review. That said, the pre-approval requirements differ depending on the product and category. For example, the following apply if you plan to sell Hoverboards:
- Your company name and seller ID
- Your contact information
- The marketplaces where you would like to sell your overboard products
- A list of ASINs you are applying to sell
- Documentation that all hoverboards and hoverboard-related products you are applying to list are certified under UL2272
- If you are a reseller of these products, a letter from the manufacturer demonstrating that you are an authorized reseller
How do I submit compliance documents and test reports to Amazon?
In many cases, Amazon.com will reach out directly to the applicant and request documentation. An example follows below:
Thank you for your application to sell [Product] in Amazon UK. You’ve reached Henry from the product category approvals team.
We are unable to approve your application based on the documents you provided. To continue processing your application, we need you to address the following issues:
1. Provide additional images. We require that you provide images that show all sides of the product, and its original packaging.
2. We need a Declaration of conformity, listing all mandatory directives and safety standards. On your application we received a test report, which we do not accept. Please, provide us with a Declaration of Conformity
3. The invoice is a commercial invoice, which we do not accept at the moment. This is a customs file and we need a sales invoice from your supplier.
In addition, we have the following requirements:
a. Invoices dated within the last 180 days, or showing item delivery or purchase within the last 180 days
In addition to the invoice, we also require the below documents:
a. Images of the [PRODUCT] where the model number and CE logos are present.
b. A Declaration of Conformity that states it is compliant with the relevant directives and compliance association
The documents can also be submitted during the pre-approval application, directly on the website. However, these documents are always reviewed manually, and Amazon often require additional files.
What can happen if I cannot show that our products are compliant?
If you cannot provide all required compliance documents, Amazon will not grant you with a category approval. However, that assumes that you are a new seller, or at least venturing into a new category.
However, a category approval is only the start. You are still responsible for ensuring that the products you sell, are safe and fully compliant.
If something would ever happen to a customer, or if Amazon is targeting a specific category of products (like they did with the Hoverboards in the past) – they can shut you down if you fail to prove compliance.
Can I get help from my supplier if something goes wrong?
No, don’t expect any help whatsoever from your supplier. I have seen so many situations with buyers importing products from Asia, only to turn to their supplier for help when the goods get stuck in customs – or they fail to provide documents required by Amazon and other marketplaces.
There are no ‘compliant’ suppliers that have a full set of compliance documents. It simply doesn’t exist.
At best, the supplier has an extremely basic understanding for the buyers need to ensure compliance with local regulations – but forget about finding a supplier with ready made DoCs and test reports.
It simply doesn’t exist.
Your supplier is not legal advisor. Don’t even think about calling them if you have neglected the compliance process until the point that you are about to get them listed on Amazon.
Instead, it’s up to you to confirm all applicable regulations, and then implement a compliance process.
Complying with labeling and packaging requirements
Basically all products are subject to labeling requirements. For example, apparel must carry care labels and material descriptions. In the United States, all products (or at least the packaging) must carry a country of origin label.
As you can see in the email above, Amazon may require photocopies of the product and its packaging, as proof of compliance with all applicable labeling requirements.
In addition, these labels must also be part of the written product description.
Can I send product certificates and test reports issued by our suppliers, to Amazon?
In most cases you cannot. At best, a supplier can provide old test reports that are valid for a related product. These test reports are crucial for assessing a suppliers capability to manufacture a ‘compliant product’.
However, old test reports cannot be used to prove compliance for your products.
For example, a REACH test report issued by your supplier in 2014, cannot be linked to a product imported by your company, years later.
In addition, regulations, such as CPSIA, require importers to test the goods on a regular basis.
Amazon surely knows how to make a risk assessment, and will not accept any document that gets thrown at them.
Unfortunately, many buyers assume that a test report as valid for the factory as a whole, which is not the case. A test report is only valid “there and then” – for the batch that was produced at that time.
Yet, a test report is only one of many documents you must create. Many products also require the importer to draft a declaration of conformity, bill of materials and other files.
How do I find out which safety standards and labeling requirements I must comply with?
Drafting these documents is generally easy, and no government approval is required in the vast majority of cases. The tricky part is to find out which regulations apply to a certain product, in your market.
Amazon.com provides general information in their guides. While the requirements are clear, they don’t cover the practical aspects of ensuring compliance when importing from Asia – which involves supplier background checks, creating the label files, communicating safety standards – and managing sample collection and lab testing.
To help you with this, we created the Starter Package, that includes the following:
- Step-by-step tutorials for ensuring compliance with all safety standards
- Document requirements overview
- Labeling requirements summary
- Label sample templates
- Supplier assessment process
In addition, you can also book lab tests with a leading compliance company – directly from the Dashboard. You can go to www.chinaimportal.com to learn more about the Starter Package and how it can help you launch your product.