Amazon TIC Compliance: Do You Need to Re-Test Your Product?
Amazon’s New TIC Compliance Rules Do You Need to Re-Test Your Product?
If you’ve recently received a compliance notice in Amazon Account Health referencing third-party Testing, Inspection, and Certification (TIC), your first reaction is usually some version of this:
“We already tested this.”
“Our supplier provided lab reports.”
“We used a third-party lab last year.”
“The lab is accredited.”
And then the real question:
Do we actually need to re-test?
Sometimes yes. Very often, no.
But the reason why matters more than the answer.
This article explains what Amazon is actually enforcing with its TIC program, how third-party labs fit into the process, and when sellers end up paying for unnecessary re-testing simply because they misunderstood how compliance now works.
What Amazon Changed With TIC
Amazon no longer evaluates compliance documents uploaded directly by sellers for certain regulated products.
Instead, Amazon now requires compliance confirmation to come directly from an approved third-party TIC provider, submitted through Amazon’s internal workflow in Account Health.
This is clearly stated in Amazon’s own documentation:
https://sellercentral.amazon.com/help/hub/reference/GUTZ2R2DD6P2UMVB
This change is not just procedural. It’s structural.
Amazon is no longer asking:
“Has this product been tested?”
They are asking:
“Did an approved TIC provider confirm compliance inside our system?”
If the answer to that second question is no, Amazon treats the ASIN as non-compliant, even if the testing itself is technically valid.
Where Sellers Get Caught
Two sellers. Same product. Same formulation. Same lab report.
Seller A assumes Amazon will recognize the existing testing and waits.
Seller B initiates a Test Request Form (TRF) and routes the same reports through an approved TIC provider.
Seller A gets enforcement.
Seller B stays live.
Nothing about the product changed.
Only the submission pathway did.
That difference explains most TIC-related enforcement we’re seeing.
How Amazon Tracks Compliance (This Part Matters)
Amazon does not track compliance based on documents.
It tracks compliance based on TRF status.
The enforcement logic is simple:
A TRF must be initiated through Account Health
An approved TIC provider must acknowledge it
The TRF must move to “in progress” status
Intent, explanations, or prior uploads do not pause enforcement.
Only system state does.
This is also shown step-by-step in Amazon’s own instructional video:
https://www.youtube.com/watch?v=8qoCMCBoMHw
Scenario 1: You Used a Third-Party Lab That Is Not on Amazon’s TIC List
This is extremely common.
The lab may be:
Recommended by your supplier
ISO accredited
Reputable
Previously accepted by Amazon
If the lab is not on Amazon’s approved TIC list, then:
Their reports cannot be submitted directly to Amazon
Their results are treated as external evidence only
An approved TIC provider must still review and validate them
The important point:
This does not automatically require re-testing.
What usually happens:
You initiate a TRF in Account Health
You select an approved TIC provider
You provide your existing lab reports
The TIC decides whether those reports can be validated and submitted
If scope, standards, variants, and traceability align, validation is often possible without new testing.
Scenario 2: You Used a Lab That Is on Amazon’s Approved List – But Outside the TIC Workflow
This is where frustration usually kicks in.
Even if:
The lab appears on Amazon’s approved TIC list
The testing was legitimate
The product hasn’t changed
Amazon accepted the reports previously
If the testing was not initiated and submitted through Amazon’s current TIC workflow, Amazon does not treat it as completed compliance under the new system.
This still does not automatically mean re-testing.
What usually happens:
You initiate a new TRF
You select the same lab (if approved for your category and store)
You provide the TRF ID and the prior reports
The lab determines whether it can validate and re-submit those reports through Amazon
In many cases, no physical testing is repeated.
The testing already exists.
It simply wasn’t anchored to Amazon’s current compliance pipeline.
This is best understood as re-attestation, not re-testing.
When Re-Testing Is Actually Required
Re-testing becomes unavoidable when:
Product variants were never fully covered
The tested configuration doesn’t match the ASIN family
Applicable standards have materially updated
Documentation lacks traceability
The TIC provider refuses to validate legacy reports
Importantly, Amazon does not decide this.
The TIC provider does.
Amazon defers to the TIC’s determination and does not arbitrate disagreements.
The Most Expensive Assumption Sellers Make
The costliest mistake isn’t failing a test.
It’s assuming:
“Our testing should already count.”
Amazon doesn’t enforce based on fairness or intent.
It enforces based on system state.
If the TRF is not active and marked “in progress,” enforcement can happen even when the product itself is compliant.
Quick Decision Summary
Valid testing alone is not enough
Listed lab ≠ completed TIC compliance
Non-listed lab ≠ automatic re-testing
Prior approval ≠ exemption
TRF status is what protects the ASIN
Understanding this before acting is the difference between controlled compliance and reactive enforcement.
How Sellers Should Think About TIC Going Forward
TIC is not a one-time hurdle.
It is an ongoing compliance control system.
Sellers who treat compliance reactively will keep getting surprised.
Sellers who treat it as an operational process stay ahead of enforcement.
The difference isn’t paperwork.
It’s understanding how Amazon now makes decisions.