Amazon's Third-Party Supplement Testing Mandate Explained

Elena M. Quattrone, James A. Boiani, Members of the Firm, and Lorrin M. Melanson, Associate, in the Health Care & Life Sciences practice, co-authored an article in SupplySide Supplement Journal, titled “Amazon's Third-Party Supplement Testing Mandate Explained.”

Following is an excerpt:

Want to sell dietary supplements on Amazon? If so, you’re not alone. Since the Covid-19 pandemic, Amazon has become perhaps the most powerful player in the dietary supplements space — taking the unusual position of serving as a major gatekeeper in dietary supplement commerce. Not surprisingly, it has chosen to relinquish some of that control to a chosen few. 

As of January 2026, Amazon is requiring all sellers of dietary supplements to demonstrate that their products have been tested to and comply with the federal Food, Drug and Cosmetic Act (FDCA) standards for food labeling (21 CFR 101) and current good manufacturing practices (cGMPs) (21 CFR 111 or 117, as applicable) through accredited third-party audits in an effort “to enhance product compliance and safety.” 

In addition, supplements for bodybuilding, joint health, sexual enhancement, sports nutrition and weight management must be further tested and demonstrated to be in compliance with NSF/ANSI 173-2023 standards — which include “test methods and evaluation criteria to allow for the determination that a dietary supplement contains the ingredients claimed on the label ... and that it does not contain specific undeclared contaminants” — or their equivalent. 

As described on Amazon’s Third-Party Testing, Inspection and Certification (TIC) page, sellers having an Amazon Standard Identification Number (ASIN) will receive notice from Amazon, obligating the seller to start the process of either assessing the validity of existing documentation or conducting new product testing as required. Sellers must then work with an approved TIC service to either test a dietary supplement or validate existing testing documents for all ASINs.

The TIC provider will ensure that dietary supplements meet the applicable FDCA laws, regulations and standards as well as Amazon policies. Private, first-party and consulting audits will not be accepted, nor will Food and Drug Administration (FDA) inspections. TIC service providers, as opposed to sellers, must submit documentation directly to Amazon on the seller’s behalf, a change from the previous process whereby selling partners submitted testing documentation to Amazon directly. 

What Amazon’s supplement review requirements cover

To determine which of their products are covered under Amazon’s requirements, sellers should examine the TIC page, in addition to the page for dietary supplements, where Amazon defines “dietary ingredients.” Amazon borrows from FDA and the Dietary Supplement Health and Education Act (DSHEA), defining dietary supplements as: 

A vitamin, mineral, herb or other botanical, amino acid or dietary substance used to supplement the diet by increasing the total dietary intake, or a concentrate, metabolite, constituent, extract or combination of the preceding substances intended for human consumption.

Amazon further indicates that:

Dietary supplements come in different forms such as powders, pills, capsules, liquid drops and oral sprays. They include, but are not limited to, categories such as vitamins and minerals, and herbs and botanicals.

It is important to note that a product that is not ingested orally will not be considered a dietary supplement by FDA or Amazon and cannot be marketed as one.

Approved third-party testing, inspection and certification providers

As of January 2026, Amazon lists seven approved third-party TIC companies for dietary supplements in the United States on its TIC page: Certified Laboratories, Eurofins, ITS-Intertek, Mérieux NutriSciences, National Science Foundation (NSF) SGS and UL-Underwriters Laboratories. Sellers who use other TIC companies will have to have their test results validated by one of Amazon’s approved TIC companies, incurring additional costs. Amazon notes that newly approved service providers are updated monthly in its most up-to-date list, located within its Seller Central site under the “Select a Provider” process menu. 

New product testing. For new product testing, the TIC service provider will “conduct tests in accordance with applicable standards and will submit test results directly to Amazon on [the seller’s] behalf.”

Existing documentation. For existing documentation, the TIC service provider “will review and determine acceptance at their discretion.” The TIC provider will also submit documentation to Amazon on the seller’s behalf. 

What to expect when working with a TIC service provider

TIC service providers appear to be on board with Amazon’s policy. Eurofins, for example, has a frequently asked questions (FAQ) page regarding compliance with Amazon’s dietary supplements policy. NSF — a World Health Organization collaborating center on food safety, water quality and medical device safety — also has a specific FAQ page. 

According to Amazon’s TIC page, sellers of dietary supplements should:  

• Select a TIC service provider from the approved list.
• Provide a Test Request Form (TRF) to the chosen TIC provider, which will provide instructions on sending product samples or existing documents. TRF submission is done through “Account health” on the Amazon Seller Central page.
• Remember their notified Amazon compliance due date when sending samples or documents to a TIC provider to allow time for testing and other issues that may arise. 
• Work directly with the TIC provider, which will share results directly with Amazon. Note that products may be subject to additional testing or evaluation at any time. 
• Potentially appeal a compliance requirement for a product by navigating to the “Appeal Request” section under “Account health.”

Compliance Fast-Track

Sellers of dietary supplements may find some additional efficiency in Amazon’s “Compliance Fast-Track” program, which allows for the automatic validation of some dietary supplement products when certified by select partners of Amazon by using existing certification data. For dietary supplement companies, the select partners participating in the Compliance Fast-Track program are BSCG Certified, Clean Label Project, GRMA, INFORMED, NSF and USP. According to Amazon, this pathway offers simplified documentation and faster processes, for no additional cost beyond the certification process, by allowing Amazon to collect all required certification materials directly from a certifying organization partner. 

However, it appears that the Compliance Fast-Track program does not encompass the testing requirements as now required through use of TIC providers. Additionally, Amazon’s approved fast-track compliance partner list differs from its current list of approved TIC partners. Therefore, dietary supplement sellers should take note of the differing lists and seek clarification where necessary to identify the pathway that best meets their needs.

Takeaways and next steps

As Amazon maintains its status as a leading dietary supplement marketplace, it wields considerable power over dietary supplement manufacturers and distributors hoping to set up shop on its platform. Non-compliant sellers may find their products removed or delisted pending appropriate third-party verification. As a result, dietary supplement manufacturers and distributors hoping to sell on Amazon’s online market will need to ensure that they have the proper third-party documentation to play by Amazon’s new rules. 

While these requirements are pre-existing for bodybuilding, joint health, sexual enhancement, sports nutrition and weight management supplements, Amazon’s expansion of third-party testing requirements for all dietary supplement sellers marks a notable increase in required documentation for all other supplements. This means increased costs and delay for sellers, who must source appropriate TIC service providers to provide the necessary third-party certifications.

Those looking to sell dietary supplements on Amazon’s marketplace should consider the partnerships that make the most sense for their business purposes. Sellers can request and compare quotes from various TIC providers to consider which pricing, services and timelines align with their needs, and those hoping to expedite the process may also consider sourcing certification from Amazon’s approved list of Compliance Fast-Track program partners. 

Epstein Becker Green Staff Attorney Ann W. Parks assisted with the preparation of this post.