Quick answer. Amazon’s Supply Chain Standards apply to third-party sellers, not only to Amazon’s own vendors. Amazon expects every product sold in its stores or sent to its fulfillment centers to be made in line with those standards, even where they go further than the law. It evaluates credible reports of forced, indentured or child labor, worker abuse, unsafe conditions, environmental harm and ethical violations, and it may ask you for documentation about your products or supply chain. If it finds a violation, it can return or dispose of inventory and suspend or end selling privileges. Separately, US Customs and Border Protection can stop imports made with forced labor under 19 U.S.C. 1307, Withhold Release Orders and the Uyghur Forced Labor Prevention Act. In both places, your protection is a mapped supply chain backed by genuine records.
Most sellers think of supply chain paperwork as one thing, an invoice that proves goods are authentic. That is only the first layer. Amazon also publishes human rights and environmental expectations for the factories behind your products, and US customs law adds its own test at the border. If you can show where a product was bought but not who made it, or from what, you are exposed on both fronts.
What Amazon’s Supply Chain Standards say about third-party sellers
Amazon’s Seller Central page titled Supply chain standards is short, and every sentence counts. It says Amazon expects all products for sale in Amazon stores or sent to Amazon to be manufactured in accordance with its supply chain standards, “even when our standards exceed the requirements of applicable law.” Being legal in the country of manufacture is not enough.
Who the standards cover
Amazon’s sustainability site says the standards apply to all suppliers of goods and services to Amazon, including selling partners, defined as retail vendors and third-party sellers. Amazon says it evaluates allegations of violations, may request due diligence evidence, and reserves the right to remove noncompliant products. The standards document also requires suppliers to pass the standards down to their own suppliers. If you sell on Amazon, you are in scope, and so is your factory.
What Amazon says it evaluates
The Seller Central page lists credible allegations or reports Amazon evaluates, including these.
- Forced, indentured or child labor
- Discrimination, harassment, or physical, verbal or psychological abuse of workers
- Environmental issues, such as hazardous waste discharges, that pose a risk to workers or the community
- Hazardous or unsafe working conditions
- Ethical violations
The page adds that Amazon may ask you for documentation regarding your products or supply chain, and points to a Responsible sourcing documentation page. If you receive a request, read that page in your own account, because the list can change.
What Amazon can do
If Amazon believes your products violate applicable laws or its policies, including the supply chain standards, the page lists possible actions. Returning inventory at your expense, immediately suspending or terminating selling privileges, disposing of inventory in fulfillment centers without reimbursement, or ending the business relationship. Amazon’s Account Health Rating policy adds that severity reflects, among other factors, whether a violation contravenes applicable laws, and that Amazon may deactivate an account immediately, regardless of score, if it suspects illegal or otherwise harmful activity.
What the full standards document expects from your factories
The Seller Central page links to the full Amazon Supply Chain Standards, published on sustainability.aboutamazon.com in many languages. Send it to your manufacturers and ask them to acknowledge it.
- Child labor. Workers must be at least 15, or older where local law or compulsory schooling sets a higher age, and workers under 18 may not do hazardous work.
- Forced labor. Work must be voluntary, workers may not pay recruitment fees (fees already paid must be reimbursed), and suppliers may not hold or confiscate passports or identity documents except where the law requires a temporary hold.
- Hours and wages. Outside special or emergency situations, a cap of 60 hours per week including overtime and at least one day off in seven. Legal minimum wages and overtime, pay stubs, and no disciplinary deductions.
- Treatment and safety. No discrimination, harassment or abuse, a confidential grievance channel, free protective equipment, emergency training at least annually, and safe worker housing.
- Environment and ethics. Required permits, safe handling of hazardous substances, no bribery, and complete records that are never falsified.
Two clauses matter most when a documentation request arrives. Suppliers must disclose subcontractors, recruitment agents and labor agents on request, and must cooperate with Amazon’s assessments, including confidential worker interviews. Amazon may suspend or end a relationship when a supplier refuses an assessment or required changes, fails to make remediation progress, or falsifies records.
| Standard area | What Amazon expects | Evidence to ask your factory for |
|---|---|---|
| Age of workers | At least 15 or higher local minimum. No hazardous work under 18 | Age verification procedure, audit finding on age checks |
| Voluntary work | No worker-paid recruitment fees. No retained ID documents | Recruitment fee policy, list of labor agents |
| Hours and wages | 60 hour weekly cap. One day off in seven. Legal pay with stubs | Time and pay record summaries, audit findings |
| Subcontracting | Disclose subcontractors and agents on request | Written list of subcontractors and material suppliers |
| Right to verify | Cooperate with assessments and worker interviews | Signed acknowledgment and audit clause in your contract |
Amazon says it audits suppliers across labor rights, health and safety, environment and ethics, rating findings high, medium or low, with high findings requiring corrective action plans. Use the same model for your own supplier reviews.
See also Amazon Seller Feedback.
Our Amazon suspension team can take this case from first review to final submission.
How the US forced labor import ban works
Amazon’s standards are a contract matter. The import ban is law, and it applies before inventory reaches a fulfillment center. This section is educational information, not legal advice. If a shipment is detained, work with a licensed customs broker or customs attorney.
The statute
19 U.S.C. 1307 prohibits importing goods mined, produced or manufactured wholly or in part in any foreign country by convict, forced or indentured labor. It defines forced labor as “all work or service which is exacted from any person under the menace of any penalty for its nonperformance” and not offered voluntarily, and it includes forced or indentured child labor. Note the words “wholly or in part”. Goods assembled in a clean factory can still be caught if a component or raw material was made with forced labor.
Withhold Release Orders and Findings
Under 19 CFR 12.42, when the CBP Commissioner finds that information reasonably but not conclusively indicates such goods are being imported, ports withhold their release under a Withhold Release Order. When the Commissioner determines goods are in fact covered, CBP publishes a Finding in the Customs Bulletin and Federal Register. Anyone outside CBP can report a belief that goods are made with forced labor, so allegations can come from workers, advocates or competitors.
CBP keeps a public list of Withhold Release Orders and Findings by country, each marked Active, Partially Active or Superseded. Several China entries are marked as superseded by UFLPA enforcement. CBP says it does not generally publicize specific detentions, so no news does not mean shipments are clearing.
What happens to detained goods
Under 19 CFR 12.43, an importer who contends detained goods are admissible must submit two documents within 3 months after importation. One is a certificate of origin from the foreign seller stating that the prohibited labor was not used at any stage, including for components. The other is a statement from the ultimate consignee showing reasonable efforts to trace the goods, their components and the labor used. Under 19 CFR 12.44, goods may be exported before seizure or abandonment. Without a Finding, goods not exported or proven admissible within 3 months are excluded, and 60 days after that notice they are deemed abandoned unless exported or protested. Where a Finding applies and proof falls short, the goods are seized for forfeiture.
The Uyghur Forced Labor Prevention Act in plain terms
The UFLPA was enacted on December 23, 2021. Since June 21, 2022, CBP presumes that goods made wholly or in part in the Xinjiang Uyghur Autonomous Region of China, or by an entity on the UFLPA Entity List, are prohibited under 19 U.S.C. 1307. The burden is reversed. The goods are presumed prohibited, and the importer must show otherwise.
The UFLPA Entity List
DHS publishes the Entity List on its website and in the Federal Register. It groups entities in Xinjiang that use forced labor, entities that recruit or transport workers with the Xinjiang government, exporters of covered products, and entities sourcing from certain government labor programs. Entries carry effective dates and DHS continues to investigate more, so recheck suppliers that were clean at onboarding.
Applicability review or exception
CBP’s sample detention attachment describes two routes. An applicability review argues the law does not apply, by showing the goods and their inputs come entirely from outside Xinjiang with no link to listed entities. An exception accepts that the presumption applies and argues that no forced labor was used. It needs full compliance with the UFLPA strategy’s due diligence guidance, complete answers to CBP, and clear and convincing evidence.
Documents CBP lists for tracing
The sample attachment gives non-exhaustive examples, namely certificates of origin, purchase orders, invoices and proof of payment, packing lists, bills of lading and shipping records, production records and supporting inventory records, production steps and chain of custody records, transportation documents, and daily manufacturing reports. It asks for a written response within 30 days of the notice date, allows extension requests to the Port Director, and requires English documents with originals where applicable. Always follow the dates on the notice you receive.
See also Amazon INFORM Consumers Act Verification.
Are you the importer, or is your supplier?
If your business is the importer of record for goods made overseas, CBP deals with you on a detention, and the certificate, statement or UFLPA response is yours to produce. Private label sellers usually sit here, and their file must reach past the factory to components and raw materials.
If you buy finished goods from a US distributor, the customs obligations generally sat with whoever imported them. You are still within Amazon’s scope, because the Supply chain standards page covers all products sold in Amazon stores. Choose distributors who can answer origin questions, and keep a written record of what they tell you. Our guide to finding a wholesale distributor covers vetting.
If you use a prep center, keep its receiving records and confirm lot identifiers survive its handling, so mixed or swapped inventory cannot break your chain of custody.
How to document a clean supply chain
A clean supply chain is a file a stranger could read and verify.
Start with a supplier list
Keep one register for every ASIN, with the supplier’s legal name, address, phone and website, the registration you checked and when, and whether the supplier is the manufacturer, a trading company or a distributor. A trading company is not the factory, so record the factory behind it. Amazon’s invoice page asks for supplier name, phone, address and website, so record them exactly as the invoices show them.
Map who made what
For each product, record the factory doing final assembly, the suppliers of major components or fabric, and the origin of key raw materials. Note what you confirmed, what the factory told you, and what you could not confirm. An honest map with marked gaps beats a confident one with hidden gaps.
Screen names against official lists
Check every factory, component supplier and exporter against the DHS UFLPA Entity List and CBP’s Withhold Release Orders and Findings list, and save dated results. Repeat when the lists change and when you add a supplier. A match means you get specialist advice before importing.
Keep the transaction trail
For each purchase, file the purchase order, final invoice, proof of payment from your business account, packing list, bill of lading and receiving record. These match CBP’s tracing categories and let you reconcile invoiced units with units sold and in stock.
Get evidence about the factory
Ask each manufacturer to acknowledge Amazon’s standards in writing, list its subcontractors and labor agents, and share its latest social compliance audit or allow one. Amazon’s supplier due diligence guidance suggests site visits or third-party audits to verify ethical practices, and contracts that make suppliers responsible for inventory with legitimate quality or authenticity complaints.
A worked example
The figures here are hypothetical. A seller imports cotton tote bags from a factory in Vietnam. It sold 8,400 units in 12 months and holds 1,600, so invoices must cover 10,000 units. It holds four factory invoices for 10,500 units, wire records, bills of lading, and mill invoices with cotton origin records for three orders. For the fourth, the factory switched mills without notice, and nothing names the new mill. The seller asks the factory for the new mill’s records, screens the mill against the Entity List, pauses that lot until the records arrive, and amends the contract to require notice before any change of material source.
When Seller Central asks you to prove your supply chain
Requests usually arrive as a performance notification and a violation on the Account Health page. Note which policy it names, which ASINs it lists and exactly what it asks for, then answer that request and nothing broader. If your account is already deactivated over sourcing, our article on supply chain suspensions covers that appeal in depth.
Amazon’s invoice standard
Amazon’s Invoice requirements for appealing a policy violation page asks for supplier name, phone number, address and website, an issue date within 365 days before the notification, quantities covering sales and in-stock inventory for each cited ASIN over the past 365 days, and clear product identifiers such as model numbers, UPC, EAN or ISBN. Files must be PDF, JPG, PNG or GIF, no larger than 10MB. You may remove pricing, but documents must be authentic and unaltered. Amazon says it might contact the supplier to verify documents, and that invoices need not be in English.
Amazon rejects invoices sent by email rather than through Seller Central, quotes and pro forma invoices, self-issued invoices, editable or manipulated files such as .xlsx or .docx, and illegible or inconsistent documents. See why Amazon does not accept receipts and know your invoices for detail.
Letters of authorization
Where the question is trademark use, Amazon’s Letter of authorization page expects a license naming licensor, licensee, grant, geographic scope and term, on the rights holder’s letterhead with an authorized signature. Invoices, distribution agreements and purchase orders are not letters of authorization, and Amazon may contact the rights owner to validate one.
See also Amazon Private Label Supply Chain Requirements.
Where to verify each claim
A reviewer can check most of what you claim. Check it yourself first and save dated proof.
| Question | Where to check | What to look for |
|---|---|---|
| What is Amazon asking for? | Account Health page, violation detail | Policy, ASINs, documents requested |
| What standard applies to my factories? | Seller Central Supply chain standards page and the full document on sustainability.aboutamazon.com | Labor, hours, safety, subcontracting and records expectations |
| Is a supplier on a forced labor list? | DHS UFLPA Entity List. CBP Withhold Release Orders and Findings page | Name and address matches, effective dates, Active status |
| Is my supplier a registered business? | Registries in the supplier’s jurisdiction. US state registries via nass.org | Legal name, active status, address matching the invoice |
| Do my invoices cover my sales? | Seller Central business and inventory reports per ASIN | Units sold over 365 days plus stock, against invoiced units |
| What does customs require on detention? | 19 CFR 12.42 to 12.44 on eCFR. CBP UFLPA page and attachment | Who submits what, by when, and the consequence of silence |
Asked to prove your supply chain?
Send us the case and we will tell you plainly what your records can and cannot support.
What to do when something goes wrong
Problems surface three ways. Amazon asks for documentation, customs detains a shipment, or you find something yourself, such as an undisclosed subcontractor. The method is the same.
Diagnose before you respond
Separate what the notice states, what your supplier claims and what you can prove. Build a timeline of onboarding, screening, shipments and the notice. Then answer one question privately and honestly. Do you know who made these goods and from what? If not, the problem is a gap in knowledge, not formatting.
Root cause, corrective actions and preventive controls
Name the specific failure. You accepted a trading company’s invoices without identifying the factory, a factory changed mills without notice, nobody rescreened after the Entity List changed, or invoices fell short after a sales surge. Do not blame the platform, competitors or customers. Corrective actions are what you have already done, with proof, such as pausing undocumented offers, obtaining genuine records, screening suppliers and replacing one you could not verify. Preventive controls are permanent changes with a named owner and start date, such as factory disclosure before a first order, contract notice of source changes, and quarterly rescreening. Our guide to writing a plan of action shows the layout.
Be honest about viability
If you cannot identify the factory, cannot obtain genuine records, or the goods trace to a listed entity, stop selling those goods and limit your response to what you can document. Never fabricate or alter a document. Our article on forged or manipulated documentation explains how that turns a gap into a far more serious case.
A routine that keeps your file ready
The mistakes we see most are treating the invoice as the whole supply chain, stopping at a trading company, screening once and never again, and letting invoice coverage drift as sales grow. A fixed routine prevents all four.
- Before the first order. Verify registration and physical presence, identify the factory and main material sources, screen every name, and get written acknowledgment of Amazon’s standards with audit and disclosure terms in the contract.
- On every order. File the purchase order, invoice, payment proof and shipping documents together, and ask whether any subcontractor or material source changed.
- Every quarter. Rescreen against updated lists, compare invoiced units with units sold plus stock per ASIN, and review Account Health.
- Every year. Refresh audits for high-volume factories, reread Amazon’s standards, and drop suppliers who will not disclose.
If your file needs reconciling against sales and stock before you can trust it, see our Amazon inventory reconciliation service.
Frequently Asked Questions
Do Amazon’s Supply Chain Standards apply to third-party sellers?
Yes. Amazon includes third-party sellers as selling partners in scope and expects all products sold in its stores to meet the standards.
What can Amazon do if my products violate the standards?
It lists returning inventory at your expense, suspending or terminating selling privileges, disposing of inventory without reimbursement, or ending the relationship.
What is a Withhold Release Order?
A CBP order to withhold release of goods when information reasonably but not conclusively indicates forced labor, under 19 U.S.C. 1307 and 19 CFR 12.42.
How long does an importer have to prove detained goods are admissible?
Under 19 CFR 12.43, within 3 months after importation. UFLPA detention notices set their own response dates.
What is the UFLPA rebuttable presumption?
Since June 21, 2022, goods made wholly or in part in Xinjiang or by a listed entity are presumed prohibited unless the importer proves otherwise by clear and convincing evidence or shows the law does not apply.
Where do I check whether a supplier is on a forced labor list?
The DHS UFLPA Entity List and CBP’s Withhold Release Orders and Findings page. Save dated records of each check.
Does Amazon require invoices in English?
No, Amazon’s invoice FAQ says English is not required. CBP’s sample UFLPA attachment does ask for English documents.
Get Help With Amazon Supply Chain Documentation
If Amazon has asked for supply chain documentation, or you want your file checked first, our team reviews sourcing records against sales and stock and helps you respond with genuine evidence. Submit your case or book a consultation. For customs detentions, also work with a licensed customs broker or attorney.
This article is educational information, not legal advice. Amazon policies and US customs rules change, so confirm current requirements on Seller Central and official government pages. Got Suspended? cannot guarantee any outcome or timeline from Amazon or CBP.
You can also see all our marketplace suspension services.
Sources
- Amazon Seller Central: Supply chain standards
- Amazon Sustainability: Supply chain human rights and standards
- Amazon Supply Chain Standards (full document)
- Amazon Seller Central: Invoice requirements for appealing a policy violation
- Amazon Seller Central: Select reliable suppliers with due diligence
- Amazon Seller Central: Letter of authorization
- Amazon Seller Central: Account Health Rating program policy
- Amazon Seller Central: Program policies
- 19 U.S.C. 1307, Convict-made goods; importation prohibited
- 19 CFR 12.42, Findings of Commissioner of CBP
- 19 CFR 12.43, Proof of admissibility
- 19 CFR 12.44, Disposition
- CBP: Withhold Release Orders and Findings list
- CBP: Uyghur Forced Labor Prevention Act
- CBP: UFLPA Attachment to the Notice of Detention
- DHS: Uyghur Forced Labor Prevention Act
- DHS: UFLPA Entity List
- NASS: State business entity registration search