Amazon's November 2, 2026 Insurance Rule: The Per-Entity Policy Audit for Brands in Enhanced-Safety Categories
From November 2, 2026, Amazon requires liability insurance in its enhanced-safety categories, regardless of sales. The policy audit, entity by entity.

By Bernardo Campelo, Forbes Business Council E-Commerce Leader, Amazon SPN Certified provider, Amazon SP-API authorized partner, and Founder of PrepVia.
On November 2, 2026, Amazon adds two requirements to its commercial liability insurance policy for sellers in its U.S. store. The headline change is the sales threshold: from that date, in the enhanced-safety categories, the $1 million policy is required whatever a seller's monthly sales are.
For a large brand, that is rarely the part that bites, because its main account is already past the $10,000 trigger. The exposure sits elsewhere: in the new legal entity that needs a certificate before it can list in those categories, in the acquired brand whose policy was written for a different company, and in the certificate that names the parent company while the selling account belongs to a subsidiary.
This guide reads Amazon's rule the way a risk or compliance team would apply it: one selling entity at a time, criterion by criterion, against the certificate that entity actually holds.
The 60-second version
From November 2, 2026, a seller with products in Amazon's enhanced-safety categories must carry a commercial liability policy of at least $1 million per occurrence and in the aggregate, regardless of sales, for new and existing listings. Everywhere else, the old trigger stays: coverage within 30 days of passing $10,000 in gross proceeds in a month, or whenever Amazon asks. From the same date, sellers based in Mainland China must obtain their policy through the Amazon Insurance Accelerator unless Amazon agrees otherwise in writing, and a compliant policy submitted before November 2 can be used until it expires. Amazon's category page, which carries no date, adds that in the 11 enhanced-safety categories it lists as of October 26, 2026, the certificate is reviewed before listing. Amazon requires the named insured to match the legal entity in each selling account's Account Info, with a trade name allowed for single-member LLCs, which is why the audit runs entity by entity.
Every Amazon requirement below was checked against the linked Amazon page on October 26, 2026.
What Changes on November 2, 2026
Amazon announced the change in the Seller Forums on September 3, 2026, and the Commercial Liability Insurance Requirements page now carries a block of requirements that apply from November 2. The existing rule does not go away. Under Section 9 of the Business Solutions Agreement, a seller must obtain and maintain commercial liability insurance within 30 days after its gross proceeds on Amazon.com pass $10,000 in a month, or whenever Amazon asks. Amazon's A-to-z claims FAQ dates that trigger to September 1, 2021.
| Seller situation | Before November 2, 2026 | From November 2, 2026 |
|---|---|---|
| Products outside the enhanced-safety categories | $1 million policy within 30 days of passing $10,000 in gross proceeds in a month, or on Amazon's request | No change |
| Products in an enhanced-safety category | Same sales trigger, except products whose own Amazon policy already required a certificate (see below) | $1 million per occurrence and in the aggregate, regardless of sales, for new and existing listings |
| Seller based in Mainland China | Any insurer that met Amazon's criteria | Policy through the Amazon Insurance Accelerator, unless Amazon agrees otherwise in writing; a compliant third-party policy submitted before November 2 stays valid until it expires |
Two product policies started earlier. Amazon's policy page for lithium battery powered smart home devices and consumer electronics lists a certificate of insurance through Business Insurance verification among its requirements, and Amazon's September 30, 2026 announcement says those requirements apply from that date, with Account Health notifications rolling out in phases through November 16, 2026. A second Amazon announcement of September 30, 2026 says the requirements for gas-fueled outdoor heating products, such as fire pots, outdoor fireplaces and patio heaters, have been live since September 23, 2026, and include a certificate of insurance through Business Insurance verification.
Amazon says it will consider exceptions to these requirements on a case-by-case basis for sellers that cannot secure a policy that meets them.
The announcement says the enhanced-safety change applies to both new and existing listings, and Amazon's help pages set no grace period for listings already live. In the same forum thread, an Amazon moderator wrote on September 4, 2026 that affected sellers get a dedicated email asking for proof of insurance within 45 days of that notice. That window comes from a forum reply, not from the help pages, and the notice a seller quoted in the forum on September 15, 2026 asked for proof by November 2, 2026. Plan to have the certificate in place by November 2, or by the date in your own notice if it is earlier.
The contract changed too. Amazon's March 4, 2026 update to the Business Solutions Agreement revised the definition of Insurance Limits: besides the $1 million figure for the United States, the agreement now allows other amounts that Amazon may require for specific product categories.
The Enhanced-Safety Categories as of October 26, 2026
Amazon keeps the list on its product categories with enhanced safety listing requirements page. As of October 26, 2026, it has 11 categories. Amazon says the list changes as categories are added and does not cover every product with these requirements, and it points sellers to Account Health for the requirements that apply to their own products.
| Category | Examples on Amazon's page |
|---|---|
| Children's products | Child restraint systems, booster seats and travel systems; children's toys; infant support cushions and nursing pillows; infant and toddler sleep products; play yards; children's portable bed rails |
| Consumable and ingestible products | Dietary supplements; ingestible over-the-counter medication; ophthalmic drug products |
| Fire-related products | Fire extinguishers; smoke and carbon gas alarms |
| General household devices | Immersion water heaters; small kitchen appliances |
| Home medical devices | Medical mobility and transfer equipment; respiratory care supplies for home use; walkers and rollators |
| Lithium battery products | E-mobility devices and accessories; lithium batteries; lithium battery powered home appliances; lithium battery powered smart home and consumer electronics; portable power supplies |
| Outdoor power and heating equipment | Electric cutting tools; gas-powered outdoor heating products; portable generators; pressure washers |
| Personal safety equipment | Climbing harnesses and ropes; fall-protection harnesses; mountaineering carabiners and helmets; safety helmets |
| Sleep products | Adult portable bed rails; mattresses |
| Transport-related products | Auto and motorcycle tires |
| Water and marine safety products | Wearable or inflatable flotation products; pool safety and access control products |
The categories are wider than their examples. Amazon defines consumable and ingestible products to include products for topical application, ingestion or consumption that maintain or improve health and appearance, and the September announcement refers to the category as "cosmetic and ingestible products", although the category page itself names no cosmetic product. Each category on Amazon's page is defined with "including, but not limited to", so check Account Health for your own ASINs rather than matching product names against the table.
Insurance is one of three requirements in these categories. The same page requires verification of notified ASINs by an Amazon-authorized third-party testing, inspection and certification provider, and says products can be picked for random surveillance testing at any time. On insurance, it is explicit about timing: the certificate comes before the listing. The seller submits it through Business Insurance verification in Seller Central, Amazon reviews it, and selling privileges are turned on once it meets the requirements.
Why the Threshold Is Not the Headline for a Large Account
For a main account already past $10,000 a month, dropping the sales trigger in these categories changes little. These situations change more:
- A new selling entity or account. A new LLC for a brand launch, an acquired company that keeps its own account, a regional entity. In an enhanced-safety category, that entity needs a reviewed certificate before it lists, rather than 30 days after its first $10,000 month.
- A new category on an existing account. A home goods brand adding a lithium-powered appliance, or a supplement line joining a food account. The policy has to cover every product listed, and the new line may sit outside what the policy was written for.
- Existing listings. The rule reaches listings that are already live. The criteria already apply today, so a long-running account whose policy was never checked against all of them should check it now; from November 2, its listings in these categories need the policy whatever its sales.
That is why the useful unit of work is the selling entity. Each one has to present a certificate whose named insured matches its own Account Info, for a policy that meets every other criterion too.
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The Policy Audit, Criterion by Criterion
The criteria below come from Amazon's Commercial Liability Insurance Requirements page and already apply today. Amazon notes they apply unless applicable law or regulation requires otherwise. The right-hand column is our suggestion for what to check.
| Criterion | What Amazon requires | What to check for each entity |
|---|---|---|
| Policy type | Commercial general, umbrella or excess liability | Which policy is being presented, and whether the limits sit on it or on a layer above it |
| Limits | At least $1 million per occurrence and in the aggregate, covering products, products/completed operations and bodily injury | Both limits shown, with products and completed operations included |
| Basis | Occurrence basis; a claims-made policy only for certain categories where occurrence cover cannot be procured, as listed in Amazon's FAQ | The basis printed on the policy; if claims-made, the Business Insurance FAQ in your Seller Central account for your categories, reviewed with your broker |
| Deductible | No more than $10,000, and listed on the certificate | The deductible on the certificate, for every policy used to meet the rule |
| Scope | Must cover all sales of products listed in the Amazon.com store | Exclusions against the catalog of that account, including lines added since the policy was bound |
| Additional insured | "Amazon.com Services LLC and its affiliates and assignees" | That exact wording |
| Sunset clause | None allowed | The policy form |
| Named insured | Must match the legal entity name in Account Info; a single-member LLC may use its trade name or DBA instead | The named insured against the Account Info of that specific seller account |
| Insurer | Global claim-handling capability and a rating of A- or better from S&P and/or AM Best, or a local equivalent where those are not used | The carrier's current rating |
| Execution | Completed in full and signed by an authorized representative of the insurer | Signature and completeness |
| Notice | At least 30 days' notice to Amazon of cancellation, modification or non-renewal | The notice provision |
At enterprise scale, look twice at these rows.
Named insured. A group may buy one liability program in the parent's name and extend it to subsidiaries. Amazon's test is narrower: the insured name must match the legal entity in the Account Info of the account presenting the certificate. Ask your broker how the named insured will read on each entity's certificate before you upload it.
Deductible. Amazon caps the deductible at $10,000 on any policy used to meet the rule and requires the amount on the certificate, so check the figure printed on each entity's certificate before you upload it.
Scope. A policy written around one product line can carry exclusions that leave another line uncovered. Amazon requires the policy to cover all sales of the products the account lists, so the exclusions have to be read against the live catalog, including lines added since renewal.
- List every Seller Central account in the group, its legal entity name in Account Info, and its brands.
- Check Account Health on every account for the requirements that apply to its ASINs, and flag each account with ASINs in one of the 11 categories or with an enhanced safety requirement shown there.
- Collect the current certificate for each flagged account, and for every other account past the $10,000 trigger or asked by Amazon, and run it against the criteria table above.
- Before a new entity, account or brand lists in one of these categories, get the policy bound and its certificate submitted and reviewed first.
- Put renewal dates on the compliance calendar, since the insurer must give Amazon 30 days' notice of cancellation, modification or non-renewal.
Sellers Based in Mainland China: The Amazon Insurance Accelerator
From November 2, 2026, a seller based in Mainland China has to obtain its policy through the Amazon Insurance Accelerator, unless Amazon agrees otherwise in writing. The September announcement adds the transition rule. From that date Amazon rejects newly submitted policies obtained outside the program, while a compliant third-party policy submitted before November 2 can be used until it expires. After it expires, the next policy has to come through the program.
For everyone else the program is optional. Amazon describes it as a network of insurers, set up with an insurance broker, that evaluate qualifying sellers, and it says sellers outside Mainland China can choose any insurer that meets its criteria. The rule names Mainland China; it does not extend to sellers based elsewhere.
What Happens When the Certificate Is Missing or Fails
Two Amazon pages describe the consequences, and neither mentions a grace period.
- Listings. The category page says products that do not comply are subject to action under the Business Solutions Agreement, including removal of the listings.
- The account. The FAQ of Amazon's A-to-z Claims Process for property damage and personal injury says that, without the required insurance, Amazon will seek reimbursement of its claim costs regardless of sales thresholds unless it agrees to waive that right, and may restrict the seller from a category or suspend the account until proof of insurance arrives, with notice.
- Claims. Under the same A-to-z process, on a customer claim of $1,000 or less, Amazon resolves it with a concession and does not seek reimbursement if the seller has provided proof of insurance. A seller required to carry insurance that has not uploaded proof gets 7 days after Amazon's notice to provide it, or Amazon expects reimbursement of the concession and may withhold it from disbursements. Above $1,000, the seller or its insurer handles the claim; if proof is on file, Amazon transfers the claim to the insurer, and if not, Amazon notifies the seller, who must respond within 7 days.
The same FAQ says Amazon may share account information with insurers, including the types of products sold, sales volume, safety complaints, claims and concessions. Renewal underwriting can draw on what happens on the account.
Whose Policy Is Whose: Where a 3PL Fits
Amazon's rule is about the seller's liability for the products it sells. It is easy to confuse with two other policies that come up when inventory sits with a prep center or 3PL.
| Policy | Who buys it | The question it answers |
|---|---|---|
| Commercial liability with products and completed operations | The selling entity | Who pays when a product sold on Amazon injures someone or damages property; this is the policy Amazon's rule is about |
| General liability and bailee or warehouse legal liability | The 3PL | The 3PL's own liability, including its legal liability for goods in its care where it carries bailee coverage, within the limits and terms it bought |
| Stock throughput or cargo | The owner of the goods | Loss or damage to the owner's inventory: cargo covers it in transit, stock throughput in transit and in storage |
No 3PL policy can stand in for the first row. Amazon's criteria tie the named insured to the legal entity of the selling account and require the policy to cover all sales of its listed products. A warehouse's policy names the warehouse. Amazon's agreement also puts the cost of shipping inventory to its fulfillment centers, including freight and transit insurance, on the seller, so if the inbound leg is insured, the seller pays for that cover; the agreement assigns the cost and does not require a transit policy. Our guide to certificates of insurance, bailee coverage and stock throughput covers the second and third rows in detail.
"A product liability policy and a warehouse policy answer different questions. Amazon's November rule is about the first one, and no 3PL contract replaces it."
Bernardo Campelo, Founder of PrepVia
PrepVia receives, inspects, labels and preps inventory in Miami and ships it into Amazon FBA. We do not sell insurance or give insurance or legal advice. Confirm each point on this checklist with your broker and your legal counsel. The policy itself is between the selling entity and its insurer, placed through its broker and reviewed by Amazon.
Frequently Asked Questions
Does Amazon require liability insurance from every seller from November 2, 2026?
No. Outside the enhanced-safety categories, the existing trigger stays: commercial liability insurance within 30 days after gross proceeds on Amazon.com pass $10,000 in a month, or whenever Amazon asks. From November 2, 2026, a seller with products in an enhanced-safety category must carry a $1 million per occurrence and aggregate policy regardless of sales.
Which categories have enhanced safety listing requirements?
As of October 26, 2026, Amazon lists 11: children's products, consumable and ingestible products, fire-related products, general household devices, home medical devices, lithium battery products, outdoor power and heating equipment, personal safety equipment, sleep products, transport-related products, and water and marine safety products. Amazon says the list changes and points sellers to Account Health for their own products.
Does the new rule apply to listings that are already live?
Yes. Amazon's announcement of September 3, 2026 says the change applies to both new and existing listings, and Amazon's help pages set no grace period. In the announcement thread, an Amazon moderator added on September 4, 2026 that affected sellers get a dedicated email asking for proof of insurance within 45 days of that notice. The notice a seller quoted in the forum on September 15, 2026 asked for proof by November 2, 2026, so plan for November 2, or for the date in your own notice if it is earlier.
What must the policy and its certificate of insurance meet?
The policy must be commercial general, umbrella or excess liability, written on an occurrence basis (claims-made only where occurrence cover cannot be procured, for certain categories listed in Amazon's FAQ), with at least $1 million per occurrence and in the aggregate covering products, products/completed operations and bodily injury. It must cover all sales of the products listed in the Amazon.com store, name "Amazon.com Services LLC and its affiliates and assignees" as additional insureds and have no sunset clause. Any deductible must be no more than $10,000 and listed on the certificate. The named insured must match the legal entity in Account Info, with a trade name allowed for single-member LLCs. The insurer needs global claim-handling capability and an A- rating or better from S&P and/or AM Best, or a local equivalent where those ratings are not valid or used in the country where the insurance is required. The policy must be completed in full and signed by an authorized representative of the insurer, and the insurer must give Amazon at least 30 days' notice of cancellation, modification or non-renewal.
Can a 3PL's or prep center's insurance satisfy Amazon's requirement?
No. Amazon requires the policy to cover all sales of the products the seller lists and ties the named insured to the legal entity of the seller account. A 3PL's policies protect the 3PL: general liability for harm it causes to others and, where it carries bailee coverage, its legal liability for goods in its care.
Do sellers based in Mainland China have to use the Amazon Insurance Accelerator?
From November 2, 2026, yes, unless Amazon agrees otherwise in writing. Amazon will reject newly submitted policies obtained outside the program, but a compliant third-party policy submitted before November 2 can be used until it expires.
What happens if a seller in an enhanced-safety category has no compliant policy?
Amazon says the products are subject to action under the Business Solutions Agreement, including removal of the listings. Its A-to-z claims FAQ adds that Amazon will seek reimbursement of claim costs regardless of sales thresholds unless it agrees to waive that right, and may restrict the seller from a category or suspend the account until proof of insurance is provided, with notice.
Final Take
The November 2 rule is short, and for most large accounts the sales trigger it removes in the enhanced-safety categories was never the constraint. The work is in the criteria that already existed: the named insured, the deductible on the certificate, the exclusions against the live catalog, the exact additional insured wording.
Run that check for each selling entity, again at every renewal and whenever a new product line goes live, and make a bound policy and a reviewed certificate the first step of any launch in one of the 11 categories, since Amazon reviews the certificate before the listing goes live.
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