Quick answer. Amazon expects a private label brand to prove four things on demand. First, that a real, identifiable business made the product, shown by supplier invoices issued directly by that business, dated within the 365 days before a notice and covering every unit you sold and hold. Second, that the product meets the safety rules for its category, shown by genuine certificates and test reports such as a Children’s Product Certificate based on testing at a CPSC-accepted laboratory, a General Certificate of Conformity, or an FCC authorization for radio devices. Third, that every claim on the listing, from “BPA free” to “Made in USA”, is backed by a document you hold. Fourth, that the brand is yours, shown by a trademark, Brand Registry and GS1 barcodes licensed to your company. Build that file before Amazon asks.

Part 1 covered Amazon’s Supply Chain Standards and the forced labor import rules behind them. This part is for the private label brand owner, who has a factory make a product and sells it under their own brand. You can document the whole chain from factory floor to detail page, which no reseller can, and you alone answer when Amazon asks who made the product, whether it is safe and whether the listing is true.

Most private label cases we see start with a file that cannot answer a simple question, not with a bad product. The invoice names a trading company the certificate never mentions, or the test report covers a different model. If you have not read it yet, start with Part 1 on supply chain standards and forced labor rules.

This article is educational information, not legal advice. Product safety and import rules carry legal obligations, so confirm your specific product with the agency concerned or with counsel.

What Amazon expects a private label supply chain to prove

Amazon has no single private label checklist. Its invoice requirements, category safety policies, claims policy and brand programs reduce to one test. Every fact on your detail page must trace to a document issued by the party who knows it.

The four questions behind every request

• Who made it? A real manufacturer with a verifiable business identity, linked to you by a completed, itemized purchase.
• Is it safe and legal to sell? The certificates, test reports and registrations that the law and Amazon’s category policy require for that exact product.
• Is the listing true? Every feature, material, certification and origin statement supported by evidence.
• Is the brand yours? Trademark rights, Brand Registry and product identifiers that point back to your company.

A reseller leans on the brand owner for most of these. You answer all four yourself.

Requests usually come from a category compliance sweep, a safety or authenticity complaint, or a listing claim that triggers review. Read each one for the exact document, standard and product before uploading anything.

Proving the manufacturer is real and is the one who makes your product

Many private label orders run through a sourcing agent or trading company. That is not prohibited. The problem starts when the invoice, the test report and the certificate each name a different company and the seller cannot explain how they connect.

What Amazon says about verifying a supplier

Amazon’s invoice requirements page lists the checks it suggests for a new supplier. Review official business documentation such as business licences, verify a physical business presence such as an office or warehouse, check business credibility and background, and verify web presence through government resources, brand websites and business directories. Amazon says it might contact the supplier to verify your document information and keeps supplier details confidential. Assume the phone number and address on your invoice will be checked.

How to verify the factory yourself

1. Get the legal entity name and registration. Ask for a copy of the business licence and confirm the registered name matches, character for character, the name on the invoice and the letterhead.
2. Check the registration with the issuing authority. Search the official government business registry in the country where the factory is registered.
3. Confirm the physical address. A factory that makes your product has a production address. Compare it with the place of manufacture that will appear on your certificates, which must state at least the city and country.
4. Establish who makes the product. If you buy through a trading company, get a written statement of which factory produces your model and keep the trading company’s invoice together with that statement. Do not present a trading company as the manufacturer.
5. Keep the evidence dated. Save the registry result, licence and address check with the date.

See also Amazon Seller Reputation and Account Health.

Our Amazon suspension team can take this case from first review to final submission.

Manufacturer invoices and how they tie to your brand

The invoice links your company to the units you sell. Amazon defines it as a record of the final transaction of goods between a buyer and a supplier, issued directly by the supplier, with an itemized list of goods received and the terms of sale. Contracts, purchase orders and payment records support it, but the invoice is the document Amazon asks for.

What the invoice must show

According to Amazon’s invoice requirements for appeals, the invoice must include the supplier’s contact information (name, phone number, address and website), a clearly displayed issue date within the past 365 days before you received the performance notification, and quantities sufficient to cover your sales and in-stock inventory for each cited ASIN over the past 365 days. It needs clear product identifiers, such as product names, model numbers or universal identifiers like UPC or EAN. For variations, it must carry the version, colour or style that matches your listing, and for bundles it must list every component.

The file must be a PDF or a JPG, PNG or GIF image, no larger than 10MB, and must document a completed, fulfilled transaction. You may remove pricing, but everything else must stay visible. The invoice does not have to be in English.

What Amazon will not accept

Tying the invoice to the brand

The invoice line rarely shows your brand, because the factory sells you a model number, so you build the link. Use the factory’s model number in your listing’s model attribute, keep it on the certificate and test report, and keep the spec sheet that says the model is made under your brand. One shared model number lets a reviewer connect everything quickly.

Quantity is the other link. If your Business Reports show 6,000 units sold in the past year and you hold 1,500 in stock, your invoices for that ASIN over the same period need to account for about 7,500 units. A seller whose only large order was placed 14 months ago has an invoice outside the 365 day window. These numbers are hypothetical, but the arithmetic is the real test. Our guide to keeping invoices in line with Amazon’s requirements covers the format questions in more depth.

See also Supplier Closed or Won’t Send Invoices? How to Prove Authenticity to Amazon Without Your Original Supplier.

Certificates and test reports by category

In the US, the manufacturer or importer certifies that a consumer product meets the safety rules that apply to it. If you import a product made to your order, the certificate is usually yours to issue and support.

Children’s products. The Children’s Product Certificate

Amazon’s policy and the Consumer Product Safety Commission define a children’s product as a consumer product designed or intended primarily for children 12 years of age or younger. Manufacturers and importers must certify, in a written Children’s Product Certificate based on test results from a CPSC-accepted laboratory, that the product complies with the applicable children’s product safety rules. The CPC and supporting test reports must be in English.

When Amazon requests a CPC, it must contain every element CPSC requires. Identification of the product in enough detail to match it to that product and no others. A citation to each applicable children’s product safety rule. The name, full mailing address and telephone number of the importer or domestic manufacturer certifying compliance. Contact details for the person who keeps the test records. The month and year and the city and country of manufacture. The dates and places of testing. The name, address and phone number of each CPSC-accepted lab whose testing the certificate relies on. Amazon adds its own conditions. Amazon may not be listed as importer, record holder or any other responsible party, and if an ASIN appears on the CPC it must exactly match the listed ASIN and takes precedence over other identifiers.

Toys carry extra conditions on Amazon

For children’s toys, Amazon’s policy names ASTM F963-23 as the applicable toy safety standard and requires listing attributes for model or part number, manufacturer or brand name, the mandatory cautionary statement and a minimum age. The lowest age on the detail page must be greater than or equal to the age grading on the test document. Amazon also requires a Certificate of Insurance through Business Insurance verification, and says sellers must work with an Amazon-authorized third-party testing, inspection and certification (TIC) provider to verify notified ASINs. The TIC provider submits documents on your behalf. If you use a lab Amazon has not authorized, an authorized provider must validate the results.

General use products. The General Certificate of Conformity

For non-children’s consumer products subject to a CPSC rule, the manufacturer or importer issues a General Certificate of Conformity. CPSC says it must be based on testing or a reasonable testing program, and that third-party laboratory testing is not a requirement for general use products. It carries the same seven types of information as a CPC, with the lab section marked not applicable when no third-party lab was used.

Electronics and radio devices

Amazon’s electronics policy prohibits products that do not comply with its radio frequency devices policy and lists specific prohibited items, including USB-C cables and adapters that do not meet USB Implementers Forum specifications and certain cylindrical lithium ion cell types such as 18650 and 21700, along with products containing them. On the regulatory side, the FCC requires radio frequency devices to be properly authorized under Part 2 of its rules before they are marketed or imported into the United States. The FCC describes three procedures, Verification, Declaration of Conformity and Certification. Certification requires testing by an accredited lab and a grant from a Telecommunication Certification Body.

FDA requires facilities that manufacture, process, pack or hold food for consumption in the United States to register and to renew those registrations every other year. A registration identifies a facility and says nothing about whether your product’s labelling and claims are lawful. Amazon’s claims policy lists “FDA Approved” as an example of a misleading certification claim, so never present a facility registration as a product approval on your listing.

FDA requires facilities that manufacture, process, pack or hold food for consumption in the United States to register, and to renew those registrations every other year. A registration identifies a registered facility. On its own, it says nothing about whether your product’s labelling and claims are lawful. Amazon’s claims policy separately lists “FDA Approved” as an example of a misleading certification claim, so never treat a facility registration as a product approval on your listing.

Checking that the lab and the report qualify

A test report is only as good as the lab and the scope behind it. CPSC states that a third-party lab is one the agency has accepted to perform the specific tests for each children’s product safety rule. A lab can be accepted for some rules and not others. Search CPSC’s laboratory database at cpsc.gov/labsearch, find the lab by name, and confirm its accepted scope includes every rule cited on your certificate.

Match the report to the product, line by line

• The model number, colours and materials on the report match the units you sell. Colour matters. CPSC’s sample certificate notes that colour can be a source of lead and each colour may need testing.
• The test date is on or before the certificate date, and the manufacture date is consistent with the production run you are selling.
• The age grade on the report supports the minimum age on your detail page.
• The report is in English, complete, and unaltered. Amazon’s compliance page states that all documents, test reports or certificates must be authentic and in their original, unmodified format.

When the factory sends you its own report

A report the factory commissioned for a similar product or another customer is a starting point, not proof. If it covers a different model, commission testing on yours. Near matches are a common reason submissions bounce.

The 2026 change at the border

CPSC’s certificate pages now carry a notice that starting July 8, 2026, importers of most regulated consumer products must electronically file certificates of compliance with US Customs and Border Protection. You need the certificate before goods arrive, not when Amazon asks. Check CPSC’s eFiling pages for whether and how the requirement applies to your products.

Fact checking your listing against the documents

Amazon’s misleading and prohibited claims policy defines claims as statements, explicit or implied, about a product’s features, performance or benefits, and applies them to images, descriptions, packaging and marketing materials. It requires claims about performance, composition, ingredients or origin to be backed by verifiable evidence and documentation. Its examples mirror private label habits. “Lasts 10 years”, “100% organic”, “Made in Italy” when the product is only assembled in Italy, “twice as effective”, and false certification claims such as “FDA Approved” or “CE Certified”.

The policy cites Section 5 of the FTC Act, prohibits disease claims without FDA approval, and requires environmental claims such as “eco-friendly” to be supported.

How to fact check every claim

Origin claims are a special trap

The FTC says an unqualified “Made in USA” claim requires the product to be all or virtually all made in the United States, meaning final assembly or processing in the US, with all significant processing and nearly all components of US origin. The company needs competent and reliable evidence for the claim and has an ongoing obligation to review it when sourcing changes. A brand that moves production overseas and leaves the old claim up has a misleading claim the day the first imported unit sells.

Country of origin marking on the product

Origin appears in three places that must agree, the product or its container, your listing, and your certificates. Under 19 CFR 134.11, unless an exception applies, every article of foreign origin imported into the United States, or its container, must be marked in a conspicuous place, as legibly, indelibly and permanently as the article allows, with the English name of the country of origin, so that the ultimate purchaser in the US can see it.

Making the three places agree

• On the product. “Made in” followed by the English country name, printed or moulded where the buyer will see it, not on a sticker that peels off in transit.
• On the listing. The country of origin attribute in Seller Central matches the marking.
• On the certificate. The place of manufacture on your CPC or GCC names the same country, plus the city or region.

Where parts from one country are assembled in another, origin becomes technical. Get advice and keep the answer in your file.

GS1 barcodes, trademarks and Brand Registry

The last part of the file proves the brand is yours, which often decides authenticity cases.

Barcodes licensed to your company

Amazon requires a unique product identifier, a GTIN such as a UPC or EAN, to create new listings in most categories, with category exceptions listed on its Product ID requirements page. GS1 US explains that GS1 barcodes identify your company as the brand owner of the product, and that GS1 Company Prefixes and GTINs are used under a licence agreement. A single GS1 US GTIN is listed at $30 with no annual renewal fee. A Company Prefix covers multiple barcodes with an initial fee and an annual renewal. GS1 notes that renewing your membership keeps your product data linked to your company.

Look your GTIN up in the GS1 database tools and confirm the company it returns is yours. See our guide on barcodes and account risk for the detail.

Trademark and Brand Registry

Amazon Brand Registry is free. It requires a pending or registered trademark for your brand name or logo, issued by the government trademark office of a country with an Amazon store. Text marks and image marks are both accepted, but an image mark must contain words, letters or numbers, and the mark text must match the brand name on the application. You must own the trademark, and the brand name or logo must be permanently affixed to your products or packaging. Enrollment gives you the Report a Violation tool and access to programs such as Transparency and Project Zero.

Check your own mark in the USPTO trademark search system, and check its status in TSDR, the Trademark Status and Document Retrieval system. Confirm the owner of record is the same legal entity that sells on Amazon. A trademark held personally by a founder while the seller account belongs to an LLC is a mismatch to fix. Our explainer on trademarks as property covers ownership in more depth.

See also How to Rebrand a Private Label Product on Amazon.

Where to verify each document

What to do when Amazon asks for documents

Amazon’s compliance page sets out the route. Open the Account Health dashboard, go to the Product policy compliance tab, choose the issue type (Food and product safety issues, or Restricted product policy violations), and click Submit in the Next steps column for the product. You can add compliance for one product or bulk upload documents. If you believe the requirement does not apply, use Appeal requirement on the same screen, select a reason and explain why.

Diagnose before you upload

Read the request for the exact document, standard and product. Then place yourself in one of three positions. You hold a genuine matching document. Or the product complies but the document is missing or mismatched, so you need real testing or a corrected certificate. Or the product cannot meet the standard.

Root cause, corrective action, prevention

If an account level action follows, the plan of action follows the standard structure with private label specifics.

• Root cause. Name the actual failure, for example “our CPC listed the factory’s model number while our listing used a different internal model number, and no one reconciled them before launch”.
• Corrective actions already taken. The corrected certificate, the new test report from an accepted lab, the listing claims removed, the units held back, each with dates and proof.
• Preventive controls. A pre-launch compliance check owned by a named person, a claim audit on every listing change, and a document review before each production order, with dates for the first run.

The line you do not cross

Never alter a certificate, edit a test report, or buy a document for a product that was not tested. If a genuine document cannot be obtained, commission real testing, fix the product, or stop selling it. We cover safety enforcement in our article on safety suspensions.

Mistakes that sink private label files

Three patterns recur. Variations are added when only one colour was tested. Packaging is redesigned and the origin marking drops off. A second factory is added and nobody updates the certificate’s place of manufacture. Each change should trigger a document review. If someone else is listing against your brand, see how inauthentic and counterfeit complaints differ.

Keeping a supply chain file ready before Amazon asks

Organise the file by ASIN, with the same folders for each, so anyone on your team can answer a request quickly.

What goes in each ASIN folder

1. Manufacturer. Business licence, registry search with date, address verification, the statement naming the factory if you buy through a trader.
2. Invoices. Every final invoice for the last 365 days and beyond, with a running total of units bought against units sold and in stock.
3. Compliance. The CPC or GCC, the test reports, the lab’s accepted scope screenshot, FCC authorization or FDA registration where relevant.
4. Claims sheet. Every claim on the listing and packaging with the document that supports it.
5. Labels and packaging. Photos of the product marking, country of origin, cautionary statements and barcode.
6. Brand. Trademark registration or application record, Brand Registry confirmation, GS1 licence.

A routine that keeps it current

• Before each production order. Re-check the factory registry, confirm the model number and materials are unchanged, and confirm testing still covers this run.
• When anything changes. A new factory, colour, material, size or packaging triggers a certificate and claim review before the units ship.
• Monthly. Reconcile units bought against units sold and in stock per ASIN so the 365 day invoice test always passes.

For brand owners who want a wider view of private label operations, our article on running a private label brand on Amazon sets out the business side.

Frequently Asked Questions

What documents does Amazon want from a private label seller?

Expect requests for final supplier invoices, category compliance documents such as a CPC, GCC or FCC authorization, evidence behind listing claims, and proof of brand ownership. The notice determines which ones, so read it for the exact document, standard and product.

Who issues the Children’s Product Certificate for a private label product?

The importer or domestic manufacturer certifies compliance. If you import your private label product, you issue the CPC, based on testing by a CPSC-accepted laboratory, and Amazon may not be listed as a responsible party on it.

Do general use products need third-party testing?

CPSC says third-party laboratory testing is not a requirement for general use products. The General Certificate of Conformity must still be based on testing or a reasonable testing program.

How do I check whether a lab is CPSC-accepted?

Search the lab in CPSC’s laboratory database at cpsc.gov/labsearch and confirm its accepted scope includes every rule on your certificate, because acceptance is granted for specific tests.

Do I need a registered trademark for Brand Registry?

Amazon accepts a registered trademark, and in some cases a pending application, from the government office of a country with an Amazon store. You must own it, and the brand must be permanently affixed to the product or packaging.

What if my product cannot pass the required test?

Then it cannot be documented honestly. Fix the product and retest, or stop selling it. Never submit an altered or purchased document.

Get Help With Private Label Supply Chain Documents

If Amazon has asked for documents you are not sure qualify, or your listings are already suppressed, send us the notice and the file you have. We will tell you plainly which documents meet the standard, what is missing and what a credible response looks like. You can submit your case for review or book a consultation to build your file before anyone asks.

This article is general educational information about Amazon policies and US product rules as published at the time of writing. It is not legal advice, and Amazon and agency requirements change. Confirm current requirements on the official pages linked below before acting.

You can also see all our marketplace suspension services.

Sources

• Amazon Seller Central: Invoice requirements for appealing a policy violation
• Amazon Seller Central: Children’s Product Certificate (CPC)
• Amazon Seller Central: Children’s toys
• Amazon Seller Central: Electronics
• Amazon Seller Central: Misleading and prohibited claims
• Amazon Seller Central: Submit compliance information or an appeal
• Amazon Seller Central: Listing requirements, Product IDs (GTINs)
• Amazon: Brand Registry
• CPSC: Children’s Product Certificate
• CPSC: General Certificate of Conformity
• CPSC: Lab accreditation and accepted laboratory search
• CPSC: eFiling
• FCC: Equipment authorization
• FDA: Registration of food facilities
• eCFR: 19 CFR 134.11, Country of origin marking
• FTC: Complying with the Made in USA standard
• USPTO: Trademark basics
• GS1 US: Get started with barcodes