The short answer
Every notified US supplement must come from a facility compliant with 21 CFR 111 or 117, or equivalent, shown by an in-date certificate from an accredited third party and validated by an Amazon-authorized TIC lab. You also need a Certificate of Insurance. Your deadline is the “Address issue by” date in Account Health, not 90 days.
The document request shows up in Account Health with a date beside each ASIN. Then LinkedIn tells you that you have 90 days.
That’s the first mistake we correct. No Amazon page says 90 days. The number came from the American Herbal Products Association (AHPA), and it was 90 days to start a lab request, not to finish. The date that protects your listing is the one Amazon shows you.
What does Amazon’s cGMP requirement actually say?
Amazon’s US dietary supplement policy says every supplement must be manufactured in a facility compliant with FDA’s cGMP rules, 21 CFR 111 or 21 CFR 117, or equivalent. The conditions:
- The cGMP audit or certification must be done by an accredited third party.
- Private audits, first-party audits, consulting audits and FDA inspections are not accepted.
- The certificate must be in good standing and cannot be expired.
- A current GFSI food-safety certification for the facility may satisfy the requirement.
Amazon lists accepted programs and says the list isn’t exhaustive. It includes NSF/ANSI 455-2, NSF 229, Eurofins, UL GMP 21 CFR 111, USP GMP, SGS GMP, TGA GMP, SSCI, ISO 22000, and GFSI-benchmarked schemes such as SQF, BRCGS and FSSC 22000.
If your manufacturer is outside the US, check the bottom of that list. Amazon also accepts EEA GMP certificates issued under EudraLex Volume 4, PIC/S GMP certificates or site licenses, Korean MFDS GMP certificates and a Health Canada site license.
Two more pieces sit beside the certificate:
- A Certificate of Insurance, submitted directly to Amazon through Business Insurance verification in Seller Central.
- Lab testing, for five categories only: bodybuilding, joint health, sexual enhancement, sports nutrition and weight management. Those need heavy-metal, microbial and adulterant testing (NSF/ANSI 173-2024 or equivalent).
How we got here: testing for three categories arrived in April 2024 and joint health in January 2025. In December 2025 AHPA reported cGMP verification expanding to all supplements, in phases.
What is the deadline: 90 days or the “Address issue by” date?
The “Address issue by” date. Amazon’s process page says to submit a test request form (TRF) to an authorized TIC lab through Account Health before that date, and send the lab your samples or existing documents.
When the lab receives your submission, it marks the TRF “in progress”. Amazon says that while it’s in progress, your listings will not be deactivated. If the product fails testing or the documents fail validation, the listing is deactivated immediately.
Two practical points:
- You can only start after the document request appears in Account Health. Before that, build the file.
- AHPA said outreach may be skipped where Amazon already verified cGMP through third parties or public databases. No notice yet can mean Amazon already verified you, or that your turn hasn’t come.
How do you submit through a TIC lab?
Amazon’s steps:
- Account Health → Policy compliance → Food and product safety issues.
- In Next steps, click Submit on the product.
- Select Verify your product, then Test (new testing) or Validate (existing documents).
- Choose the provider, then share the Order ID and TRF details with them.
The authorized TIC providers for US dietary supplements are Certified Laboratories, Cotecna, Eurofins, ITS-Intertek, Mérieux NutriSciences, NSF, SGS and UL. USP isn’t on that list, even though a USP GMP certificate is an accepted program.
You can use another accredited lab, but an authorized TIC must then validate its results. The lab submits for you, not you to Amazon.
If no TRF option shows on the ASIN, submit an appeal and Amazon reassigns the workflow. If you believe the requirement doesn’t apply, use Appeal request on the same screen. For bundles, multipacks and variants, agree the approach with the lab.
One shortcut exists. If your product is certified by a Compliance Fast Track participant (for supplements: BSCG Certified, Clean Label Project, GRMA, INFORMED, NSF, SGS or USP), Amazon says it validates compliance automatically, without documents from you.
What documents and images will the lab need?
Amazon’s document rules apply to everything you send:
- Authentic, original and unmodified. Not computer or AI-generated.
- Not from a lab Amazon has suspended.
- Labels in the language of the country of sale.
- Images that show all sides, and show the product is the same as the one tested and listed.
- Separate documents and images for each item in a set or bundle.
Where this goes wrong
Waiting for day 90. The protective step is a TRF marked “in progress” before Amazon’s date.
Sending an FDA inspection report. It doesn’t count for supplements, though it does for ingestible OTC drugs.
An expired certificate. Treat it as no certificate.
Forgetting the insurance certificate. It goes to Amazon separately from the lab work.
A rewrite that triggers testing. Changing a claim to “supports metabolism” can move the product into weight-management testing.
Treating a pass as permanent. Amazon says products can be picked for periodic or random surveillance testing at any time. Keep the certificate in date and the file ready.
How we work
What we check on every supplement account before the date
This is how we work, on every supplement account with a notice:
- Copy the notice word for word from every place it appears, and log each ASIN’s “Address issue by” date.
- Check the certificate: accredited body, accepted program, the facility that makes the product, in date.
- Check the insurance certificate is in Business Insurance verification.
- Check the label images are real photos of the real product, all sides, and that panel weights match the listing.
- Check whether any claim pulls the product into one of the five testing categories.
- Submit once, in one channel, then run the reply clock.
- Scan the rest of the catalog for ASINs that will get the same notice.
FAQ
How does Amazon decide my product is a dietary supplement?
From the listing, label and marketing. Amazon names a Supplement Facts panel, a “Dietary Supplement” label statement, claims about vitamins, minerals, herbs or amino acids, dosing instructions such as “take 2 capsules daily”, and health or structure/function claims. A Nutrition Facts panel doesn’t keep you out if the listing shows any of these.
Is USP an Amazon-approved lab for supplements?
Not as a TIC lab. USP isn’t on Amazon’s authorized TIC list for US dietary supplements. A USP GMP certificate is an accepted cGMP program, and USP is a Compliance Fast Track participant for supplements, which is a different route.
Does a recent FDA inspection satisfy the cGMP requirement?
Not for supplements. Amazon says FDA inspections will not be accepted. You need a third-party audit or certificate from an accredited body.
Does every supplement need lab testing?
No. Testing applies to five categories: bodybuilding, joint health, sexual enhancement, sports nutrition and weight management. Every notified supplement needs the cGMP verification.
Does this apply on Amazon UK or Germany?
Not the TIC process, which Amazon lists for the US store only. Amazon UK and Amazon.de have their own rules: you apply for approval to sell food supplements and submit a GFSI, HACCP or GMP certificate for the manufacturer, per ASIN.
About UPLIXA. UPLIXA is a compliance-first Amazon agency founded in 2021. We have worked with 80+ brands across the US, UK and Germany and handled 5,000+ listings across our services, from compliance and listing reinstatement to brand protection and brand name recovery.
