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Amazon's New $1 Million Liability Insurance Rule: Which Sellers Need Coverage Now and How to Stay Compliant

Short answer: Since November 2, 2026, any seller on Amazon.com with products in a category that carries enhanced safety listing requirements, such as children’s products, cosmetics and ingestibles, or lithium battery products, must hold commercial liability insurance of at least USD 1 million per occurrence and in the aggregate, whatever its monthly sales. The rule covers new and existing listings. Sellers based in Mainland China must also buy any newly submitted policy through Amazon Insurance Accelerator (AIA). Everyone else still falls under the older rule: insurance within 30 days of any month with more than USD 10,000 in Amazon.com gross proceeds (Amazon Seller Forums announcement).

For established manufacturers adding Amazon as a channel, and for overseas brands selling into the US, this changes the order of work. Insurance used to be something a brand could arrange after sales grew. In these categories, it now has to be on file before the listing is safe.

What changed on November 2, 2026?

Amazon announced the update on its US Seller Forums on September 3, 2026 (PPC Land). It keeps the existing requirement and adds two triggers (Amazon Seller Forums):

  1. A product trigger. Sellers with products listed in categories with enhanced safety listing requirements must keep a policy “that covers those products,” with at least USD 1 million per occurrence and in aggregate, “regardless of whether they meet the USD 10,000 gross proceeds in a month threshold.”
  2. A location trigger. Sellers based in Mainland China must obtain insurance through AIA. From November 2, Amazon rejects newly submitted policies not obtained through AIA. A compliant third-party policy submitted before November 2 stays valid until it expires, and the renewal must then come through AIA.

Amazon gives its reason as protecting customers and helping sellers “protect your business from financial loss in the event of a product-related incident” (Amazon Seller Forums).

Which sellers need coverage now?

Two questions decide it: what you sell, and where your business is based. Sales volume matters only if neither new trigger applies.

Your situation Insurance required? Where to buy it
Any product in an enhanced-safety category, any sales level Yes, USD 1M per occurrence and aggregate, covering those products Any insurer meeting Amazon’s criteria, unless based in Mainland China
No enhanced-safety products, over USD 10,000 gross proceeds in a month Yes, within 30 days Any insurer meeting Amazon’s criteria, unless based in Mainland China
No enhanced-safety products, never over USD 10,000 in a month Not under these triggers, unless Amazon requests it Not applicable
Based in Mainland China, submitting a new policy Yes, if either trigger above applies AIA, unless Amazon agrees otherwise in writing
Based in Mainland China, compliant policy submitted before Nov 2, 2026 Covered until that policy expires AIA at renewal

Sources: Amazon Seller Forums; PPC Land, citing Amazon’s Commercial Liability Insurance Requirements page.

The “unless Amazon requests it” line matters. The baseline rule has always let Amazon ask for insurance outside the threshold (PPC Land).

Which categories count as “enhanced safety”?

Amazon names three examples, children’s products, cosmetic and ingestible products, and lithium battery products, and says the list “include[s], but [is] not limited to” them. It points sellers to its page of product categories with enhanced safety listing requirements for the full set (Amazon Seller Forums).

That page is not final either. Sellers in the same thread quote it as saying the list “changes as Amazon adds new categories, and it does not cover all products with these requirements” (Amazon Seller Forums). Some product types sit close to a boundary, such as a herbal tea that could be classed as a grocery item or a supplement, or a household device with a built-in lithium battery. In those cases, assume the stricter reading until Amazon confirms otherwise.

Two lists can change underneath you: Amazon’s category list, and how Amazon classifies a given ASIN. Check both, not one.

What must the policy include?

PPC Land summarized the criteria on Amazon’s Commercial Liability Insurance Requirements page as of November 2, 2026 (PPC Land). Use this as a review checklist for the certificate of insurance before you upload it:

  • Policy type: commercial general, umbrella or excess liability.
  • Basis: written on an occurrence basis. A claims-made policy is allowed only where an occurrence policy can’t be obtained for certain product categories that Amazon lists in its FAQ.
  • Limits: at least USD 1 million per occurrence and in aggregate, covering products, products/completed operations and bodily injury.
  • Deductible: no more than USD 10,000, and shown on the certificate.
  • Scope: covers all sales of products you list on Amazon.com.
  • Additional insured: Amazon.com Services LLC and its affiliates and assignees.
  • No sunset clause, and at least 30 days’ notice to Amazon of cancellation, modification or non-renewal.
  • Insurer strength: global claim handling and a rating of S&P A- and/or AM Best A- or better, or a local equivalent where those agencies aren’t used.
  • Name match: the insured name matches the legal entity name on the seller account. Single-member LLCs may also use a trade name.

The scope line deserves attention. The forum notice speaks of a policy that covers “those products,” but the requirements page asks for coverage of all sales from all listed products and describes no narrower policy (PPC Land). Ask your broker to write the policy to the full Amazon.com catalog rather than only the enhanced-safety SKUs.

Amazon also says it will consider exceptions case by case for sellers who can’t secure a compliant policy (PPC Land). It doesn’t publish a timeline for those decisions, so don’t plan a launch around one.

How should a manufacturer or overseas brand respond?

This is the sequence we’d follow for a brand with an existing Amazon catalog, or one preparing to list.

  1. Map the catalog. Export active and inactive listings and mark every ASIN that falls in or near an enhanced-safety category. Include bundles and accessories: a toy sold with batteries is both a children’s product and a battery product.
  2. Check the account, not just the catalog. Look in Account Health and your Seller Central messages for any insurance request tied to the November 2 change. Sellers reported receiving emails asking for proof of cover by November 2, 2026 (PPC Land).
  3. Confirm which entity holds the account. The insured name must match the legal entity on the account. Groups that sell through a US subsidiary but insure the parent company, or the reverse, should fix that before buying cover.
  4. Decide where to buy. Sellers based in Mainland China submitting a new policy go through AIA. Everyone else can use their own broker, as long as the policy meets every criterion above. A brand’s existing home-market product liability policy usually needs an endorsement or a separate US policy to satisfy the additional-insured, notice and territory points. Ask the insurer to confirm each one in writing.
  5. Review the certificate against the checklist before uploading. The most common gaps are the deductible missing from the certificate, the wrong Amazon entity named as additional insured, and an insured name that doesn’t match the account.
  6. Set a renewal reminder at least 45 days ahead. Amazon requires 30 days’ notice of non-renewal from the insurer. Your own reminder should come earlier, so a lapsed renewal never reaches the account.
  7. Recheck quarterly. Amazon adds categories to the list. A product that was outside it at launch can move inside it later.

Insurance sits alongside the product-safety documents Amazon already asks for. It doesn’t replace them. Our guide to Amazon product compliance covers the certificates and test reports. Our post on Amazon restricted categories covers category approval, which is a separate gate.

Example: a brand under the USD 10,000 threshold

Assumptions, for illustration only: an established European skincare manufacturer launched on Amazon.com this year with six SKUs. It has never had a month above USD 10,000 in gross proceeds. It sells through a US LLC and is not based in Mainland China.

  • Before November 2: no insurance was required unless Amazon asked for it.
  • From November 2: cosmetics are named as an enhanced-safety category, so the brand needs a USD 1 million policy now, at its current sales level (Amazon Seller Forums).
  • What it buys: a US policy, or an endorsement to the parent’s policy, issued to the US LLC’s exact legal name. It names Amazon.com Services LLC as additional insured, carries a deductible of USD 10,000 or less shown on the certificate, and covers all Amazon.com sales.
  • What it still needs separately: the cosmetics documents Amazon and the FDA already expect, covered in our MoCRA guide.

No premium is shown here. Amazon hasn’t published prices for sellers caught by the new trigger, and quotes depend on product, claims history and insurer (PPC Land).

What Amazon hasn’t said yet

Amazon’s published documents leave several points open (PPC Land): how many sellers or listings the category trigger affects, what happens on day one to a seller without cover, how fast exception requests are decided, and whether other Amazon marketplaces will follow. The notice applies to the Amazon.com store only. Watch Account Health, not forum threads, for what applies to your account.

FAQ

Does the USD 10,000 threshold still apply? Yes. It still applies to every seller. The category trigger adds a second route to the same requirement (Amazon Seller Forums).

Does the rule apply to listings created before November 2? Yes. Amazon says the change applies to both new and existing listings (Amazon Seller Forums).

Can I use a claims-made policy? Only where an occurrence-based policy can’t be obtained for categories Amazon lists in its FAQ, or with an exception Amazon grants case by case (PPC Land).

We’re a manufacturer outside China. Do we have to use AIA? No. The AIA requirement applies to sellers based in Mainland China. Other sellers can buy from any insurer that meets Amazon’s criteria (Amazon Seller Forums).

Does this rule apply outside the US? The notice covers the Amazon.com store. If you sell in other Amazon marketplaces, check each one’s own requirements. Our post on expanding internationally on Amazon covers running more than one marketplace.

How AEG helps

AEG Accelerator has worked with established companies, manufacturers and growing brands for almost two decades across Amazon, Walmart, Shopify/DTC and wholesale. Compliance gates like this one are part of our marketplace brand management work. We map the catalog against Amazon’s requirements, work with your broker on the certificate, and keep listings live while the business grows.

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