On 3 September 2026 Amazon announced two changes to its commercial liability insurance requirement, both effective 2 November 2026. If you have listings in a category with enhanced safety listing requirements, you will need a $1 million policy covering those products even if you have never crossed $10,000 in gross proceeds in a month — the threshold that has been the trigger until now. Separately, sellers whose business is based in Mainland China must obtain that policy through the Amazon Insurance Accelerator.

This is a quiet announcement with a real deactivation risk attached, and it lands in the worst possible window: Amazon says it will email affected sellers and give them 45 days to produce proof. Count 45 days from an email that arrives in October and you are producing a certificate of insurance in the middle of Q4.

What changed

  • The sales threshold stops being the only trigger. Amazon’s requirement has historically applied once a seller exceeds $10,000 in gross proceeds in a month. From 2 November, listings in categories with enhanced safety listing requirements need coverage regardless of volume. A brand doing $2,000 a month in a covered category is now in scope.
  • The coverage bar itself is unchanged: commercial general, umbrella or excess liability, occurrence-based, a minimum of USD 1 million per occurrence and in the aggregate, a deductible no higher than $10,000, and Amazon.com Services LLC and its affiliates and assignees named as additional insured. Those terms are set out on Amazon’s own publicly readable Seller Central forums.
  • Which categories count is not fully public. Amazon’s announcement names children’s products, cosmetic and ingestible products, and lithium battery products — and says the list “includes, but is not limited to” those. The complete enumeration lives on the gated help page inside Seller Central, so read it from inside your own account rather than trusting a third-party list, ours included.
  • Mainland China sellers lose insurer choice. From 2 November, Amazon will reject newly submitted policies from these sellers that were not obtained through the Amazon Insurance Accelerator. The test is where the business is based, not where the goods are made — a US-based brand manufacturing in China keeps its existing insurer.
  • Existing policies are grandfathered to expiry. A compliant policy submitted before 2 November can run until it expires; the renewal is what has to come through AIA.
  • The enforcement mechanism is email plus 45 days. Amazon says it will notify sellers it determines need new or updated coverage, and that listings in enhanced-safety categories may be deactivated until compliant documentation is provided.

What it means for a private-label seller

The interesting part is not the insurance. Most brands over $50k a month already carry a $1M policy, because they crossed the $10,000 threshold years ago and Amazon made them. The interesting part is who this catches: the small, new, or seasonal ASIN in a covered category, sitting inside an account whose insurance was never a live question.

Three practical consequences.

First, it is a listing-level risk, not an account-level one. The consequence Amazon describes is deactivation of listings in the affected categories — so a supplement or a battery-powered SKU can go dark while the rest of the catalogue keeps selling. That is worse than it sounds for advertising: a deactivated ASIN stops serving, campaigns keep their structure, and your spend redistributes to whatever else is in the ad group. You do not get an alert that says “your insurance killed this campaign.”

Second, the 45-day clock is not yours to schedule. It starts when Amazon’s email lands, and Amazon has not published a notification calendar. Certificates of insurance with a specific additional-insured wording are not same-day items from most brokers; a first-time policy in a product-liability category can take a couple of weeks. If that request arrives in mid-October you are negotiating cover while inbounding Q4 stock.

Third, this is a real cost line for small SKUs. If you have a single low-volume ASIN in a covered category and no policy today, the honest maths may be that the annual premium exceeds what that SKU contributes. That is a discontinue decision, not a compliance decision, and it is better made in September than under a deactivation notice.

One thing this is not: a new rule about product safety testing. It does not change your CPC, GPSR, or lithium battery documentation obligations. It changes who has to be insured.

What to do about it

  1. Check the enhanced-safety category list inside Seller Central, not outside it. Open the Commercial Liability Insurance Requirements help page from your own account and match it against your catalogue. The public examples — children’s products, cosmetics and ingestibles, lithium battery products — are the start of the list, not the whole of it.
  2. If you already carry a compliant policy, confirm three things: the $1M per-occurrence and aggregate limits, a deductible at or under $10,000, and Amazon.com Services LLC named as additional insured. A policy that meets the limits but omits the additional-insured wording is the most common rejection we see, and it is a one-email fix with your broker.
  3. If you do not carry one and you sell in a covered category, start the quote now. Getting a certificate in hand before Amazon’s email arrives converts a 45-day scramble into an upload.
  4. Mainland-China-based sellers: check your renewal date against 2 November. If your policy renews after that, plan the move to the Amazon Insurance Accelerator now rather than discovering the rejection on submission.
  5. Everyone else: nothing to do yet, but do not delete the email. Amazon’s notification is the thing that starts the clock, and it will not look urgent.

Sources

The full enumeration of enhanced-safety categories is only available on the gated Seller Central help page, so it is deliberately not reproduced here. Verify against your own account.