Amazon’s commercial liability insurance rule changes on November 2, 2026. For products in Amazon’s enhanced-safety categories, the $10,000 monthly sales threshold no longer applies. If you list children’s products, supplements, cosmetics, lithium battery products, small kitchen appliances, mattresses, tires, helmets or anything else on that list, you need $1 million per occurrence and $1 million aggregate in coverage from the first listing, whether the ASIN sold $80 last month or $80,000. It applies to listings already live.
Updated September 2026. This post replaces our 2021 guidance on Amazon insurance for non-resident sellers. The 2021 approach, forming a U.S. LLC to obtain a certificate of insurance, is covered below as history, not as a recommendation.
For a foreign-owned brand, the policy is the small problem. The bigger one is whether your existing company can get that coverage at all, and what happens to your Amazon account if it cannot. That second question is where sellers got hurt in 2021, and it is the one this post is about.
What Changed in Amazon’s Insurance Requirements
Amazon’s existing rule stays in place. Once gross proceeds from Amazon.com pass $10,000 in a month, you have 30 days to carry commercial liability insurance with $1 million per occurrence and aggregate, products and completed operations included, naming Amazon.com Services LLC as additional insured. Any qualified insurer.
As of November 2, two things are new.
The threshold is gone for enhanced-safety categories. A listing in one of those categories needs the full policy regardless of volume, new or existing. Amazon has said sellers who need new or updated coverage will get an email and 45 days to provide proof, and that affected listings can be deactivated until acceptable proof is on file.
Sellers based in Mainland China must buy through the Amazon Insurance Accelerator. Newly submitted policies from Mainland China sellers that did not come through the Accelerator will be rejected. A valid policy submitted before November 2 stands until it expires.
Do not confuse the two. The China rule is about where you buy the policy. The category rule is about whether you need one at all, and it applies to a UK supplement brand or an Australian children’s brand exactly the way it applies to a seller in Shenzhen. Sellers outside Mainland China keep their choice of insurer.
The categories Amazon has named so far: children’s products (toys, car seats, infant sleep products, play yards, bed rails); consumable and ingestible products (dietary supplements, OTC medication, ophthalmic products, and topicals including skincare and cosmetics); lithium battery products (batteries, power banks, e-mobility, battery-powered appliances and electronics); personal safety equipment (helmets, climbing and fall-protection gear); outdoor power and heating equipment; small kitchen appliances; home medical devices; mattresses and adult bed rails; fire extinguishers and alarms; flotation and pool safety products; and auto and motorcycle tires. Amazon has said the list will keep growing. Check Account Health for your specific ASINs.
Can a Foreign Company Get the Coverage at All?
The announcement does not answer this, and it is the question that decides everything else. In 2021, when Amazon first pushed the $10,000 rule, the problem for foreign sellers was never finding a broker who would take an application. The problem was finding a carrier willing to accept U.S. product liability exposure on a company domiciled in Australia, the UK, Israel or Germany, especially when the product was a supplement or had a battery in it.
We saw a second version of the same problem in early 2024. Several non-resident sellers holding policies from the overseas branches of U.S. carriers had those policies cancelled, and the cancellation was reported to Amazon, as the carrier is required to do. The seller found out when the Seller Central notice arrived.
Marsh, which administers the Insurance Accelerator, describes the program as built for U.S.-based sellers and says availability depends on where you are located and what you sell. That is the same bottleneck five years later, now attached to the product classes underwriters like least. Amazon is expanding mandatory coverage into lithium, ingestibles and children’s products, which are the exact categories many standard carriers have carved out entirely.
The reason Amazon requires the coverage is the same reason a standard carrier declines it.
A Declined Application Does Not Mean You Need a U.S. LLC
When the Accelerator or a standard carrier declines a foreign company, sellers hear “you need a U.S. entity.” That is one possible answer. It is usually not the first one.
There are two insurance markets. The admitted market has state-filed rates and a conservative appetite. The surplus lines market exists for the risks the admitted market will not write, and it is reached through a broker licensed for it. Lithium, supplements with functional claims and children’s products are placed in surplus lines every day. A decline is information about which market you were shopping in. It is not a verdict on your company.
Then look at the whole number. In 2021 the quotes we saw for supplements, children’s items, cosmetics and sporting goods ran $1,000 to $10,000 a year, with about $3,500 typical, and surplus lines pricing today can sit at the top of that range. That sounds expensive until you compare it with forming a U.S. company, insuring it, moving the Amazon legal entity, going through verification again, changing banking, moving inventory, retaking the tax interview and adding a U.S. tax filing. The expensive foreign policy is often the cheap option.
One more number. If the affected ASIN does $2,000 a month and the only available policy runs $4,000 a year, the honest answer may be to pull the listing. A restructure only makes sense for a brand with enough revenue in the category to carry a U.S. operating company and everything that comes with it.
And check what you already hold. Amazon cannot tell the difference between a policy rated for an online retailer and one rated for an importer or manufacturer. The carrier can, and it matters at claim time. A private-label brand importing from China carries the product exposure itself, and a retailer-rated policy may not respond the way the seller expects.
The Certificate LLC of 2021, and Why We Do Not Do It That Way Anymore
When Amazon made its first insurance push, foreign sellers got notices with short deadlines and panicked. Our office helped many foreign-owned Amazon businesses form U.S. entities that year in connection with the insurance issue. Then Amazon did not enforce the rule the way sellers expected. Notices kept arriving, accounts stayed active, and a year later many of those sellers had an LLC they did not need and a Form 5472 filing they did not know about.
Some of those setups had a deeper problem. The pattern was a foreign company that kept operating the Amazon account, owning the inventory and collecting the payouts, while a new U.S. LLC existed mainly to hold a policy and produce a certificate Amazon would accept. Take a UK supplement brand, call the owner Adrian. His Wyoming LLC had a clean certificate on file. His UK company sold every unit. If a serious claim had come in, the carrier’s first question would have been which company actually sold the product, and the answer was not the one on the policy.
Amazon’s own rules made that shortcut easy. For a single-member LLC, Amazon accepts an insured name that matches either the legal entity or the trade name the business uses publicly. That exception solves Amazon’s document check. It does nothing for the underwriter’s question about who sold the product.
The objective was never a certificate Amazon accepts. The objective is real coverage for the business that is actually selling the products.
Do Not Change Your Amazon Entity to Solve an Insurance Problem
If an underwriter tells you they will insure a U.S. company but the U.S. company has to be the one operating the business, you are no longer buying a policy. You are moving the Amazon account, the inventory, the payouts and the tax interview to a new entity, and each of those has a compliance consequence attached.
Two of them cost real money if they happen in the wrong order. A foreign-owned single-member LLC does not automatically become the U.S. taxpayer Amazon’s tax interview expects, so the entity type has to be decided before the account changes, not after. And a foreign company already selling into the U.S. may have a federal filing question that adding a U.S. company changes rather than removes. Which structure fits depends on the home country, where inventory sits and where the profit is supposed to land. That takes an actual review by someone who signs the return.
Changing the legal entity on an established seller account is also not a mailing-address edit. Business information, taxpayer information, banking and verification documents all have to line up, and a mismatch during that transition is one of the more common ways an established account ends up in review.
Do not let an insurance requirement choose your U.S. tax structure by accident.
Will Amazon Actually Deactivate Listings?
Amazon has said what happens: affected listings can be deactivated until compliant proof is accepted. What nobody knows yet is how consistently Amazon will apply it. In 2021 the notices went out, many sellers ignored them, and most accounts kept running.
The difference this time is structural. The rule attaches to specific ASINs rather than to a seller’s monthly total, which is far easier to enforce at the listing level than the old rule was at the account level. Whether Amazon uses that capability aggressively is something to watch, not something to bet the fourth quarter on. The 45-day clock starts when the email lands, and for a lot of sellers that email will land in November.
Three Questions to Answer Before November 2
Does my product now require insurance? Check your ASINs against the enhanced-safety list in Account Health. Do not assume a product is outside the rule because you have stayed under $10,000 a month.
Can my existing company get the coverage, and at what premium? Try the Accelerator where it is available to you, then a broker who works both the admitted and surplus lines markets. Get the number before you decide anything. For our non-resident clients, that broker is Well Insurance. Matt Lovell has placed Amazon product liability for foreign-owned sellers since the 2021 rollout and knows what Amazon’s reviewers accept and what they bounce.
If a carrier requires a U.S. operating company, what does that actually change? Find out exactly what the carrier needs the U.S. company to be. Then work out the entity type, the tax position and the Amazon transition before forming anything or touching Seller Central.
For most foreign sellers the answer to question two settles it: keep the existing company, buy a real policy, change nothing structural. For brands with meaningful revenue in a high-risk category, question three may force a larger U.S. decision. If it does, the order matters.
If the Carrier Is Pointing You Toward a U.S. Operating Company
Stop before you form anything. We built the CEO Blueprint for exactly this decision, and every level starts the same way: a written answer on your actual facts, before any execution.
Decision Review, $1,250. One written answer to one question: is moving the Amazon business to a U.S. entity worth doing for your facts, and if so, in what order. For the seller who has a carrier’s answer in hand and needs to know whether the restructure is real before spending anything else.
Expansion Blueprint, $2,500. Everything in the Decision Review, plus the map: insurance, entity type, tax classification, Amazon legal-entity transition, tax interview and banking, sequenced so nothing inside Seller Central changes until the structure behind it is settled.
Do not start with the LLC. Start with the plan.
Not Sure What You Are Dealing With? Start With a Conversation.
If you have received an Amazon insurance notice, or a carrier has declined your foreign company, and you want to understand your options before you make a move, book a discovery call with our team. On the call, we will learn about your specific situation, identify the structural issue, and tell you whether and how we can help, along with the fees and timeframe involved. No strategy is provided on the discovery call. It is a focused diagnostic conversation.
Frequently Asked Questions About Amazon’s 2026 Insurance Requirements
Q: Do I need Amazon insurance if I sell less than $10,000 a month?
A: Beginning November 2, 2026, the $10,000 monthly threshold no longer protects sellers with products in Amazon’s enhanced-safety categories. Those sellers must maintain at least $1 million per occurrence and aggregate coverage regardless of sales volume. If none of your products are in a listed category, the $10,000 threshold still governs.
Q: Does the new rule apply to products I already sell?
A: Yes. Amazon’s announcement states the enhanced-safety insurance requirement applies to both new and existing listings.
Q: Do all foreign sellers have to use the Amazon Insurance Accelerator?
A: No. The mandatory Accelerator rule applies only to sellers based in Mainland China. Sellers everywhere else keep their choice of insurer, though availability depends on location, product and carrier appetite.
Q: If my foreign company cannot get insurance, do I need a U.S. LLC?
A: Not necessarily. First determine whether a broker licensed in the surplus lines market can cover the existing foreign entity. If a carrier will only insure a bona fide U.S. operating company, then entity and tax planning has to happen before formation, because the U.S. company may need to become the actual Amazon seller.
Q: Can I use a foreign-owned single-member LLC to take over my Amazon account?
A: Possibly, but forming one does not solve the tax-interview question by itself. A foreign-owned single-member LLC is generally disregarded for federal income tax purposes unless another classification is elected. Which classification fits depends on your facts and has to be decided before the account is changed.
Q: What happens if I do not provide proof of insurance?
A: Amazon has said listings in enhanced-safety categories may be deactivated until compliant proof is accepted. This is a listing-level action, not an account suspension, and it is reversible once acceptable proof is on file. The risk is timing: a 45-day clock that starts in November runs through the highest-revenue weeks of the year.
Q: Should I wait until Amazon sends me an insurance notice?
A: For an established foreign brand selling an affected product, no. Find out now whether your existing company is insurable and what the realistic premium is. If a U.S. operating structure may be necessary, November and December are poor months to discover that after the fact.
How We Got Here: Five Years of Amazon Insurance Changes
September 2021. Amazon begins requiring $1 million liability coverage once a seller passes $10,000 in monthly gross proceeds. Non-resident sellers receive 30-day notices. Many form U.S. LLCs to obtain a certificate.
March 2022. Sellers who received notices in September and October are past 90 days with accounts still active. Enforcement proves inconsistent.
June to August 2022. Amazon briefly requires zero-deductible policies for sellers under $1 million in sales, then reverses after seller pushback. Deductibles up to $10,000 are allowed again. Amazon also confirms a single-member LLC may use either its legal name or its trade name as the insured name.
February 2024. Non-resident sellers holding policies from overseas branches of U.S. carriers see those policies cancelled and reported to Amazon.
August 2024. Amazon sends mass certificate requests for non-U.S. marketplaces including Canada, the UK and the EU.
September 2026. Amazon announces the November 2 change: the $10,000 threshold ends for enhanced-safety categories, and Mainland China sellers must buy through the Insurance Accelerator.
This is educational content based on our experience working with non-resident Amazon sellers through every version of Amazon’s insurance requirement since 2021. It is not legal, tax or insurance advice. Scott Letourneau holds the MSCTA® (MainStreet Certified Tax Advisor) credential; we work with independent tax attorneys and CPAs for legal and tax execution. Amazon policies and insurance underwriting change, and availability depends on the seller, product, location and carrier. Amazon makes all seller approval, restriction and enforcement decisions. Confirm current requirements in Seller Central before acting.
