A Product Safety Misadventure Part 1: Who You Partner With Matters

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Our specialty is understanding compliance on Amazon.

I recently worked with a client who appeared to be the target of a dirty seller trick – a review was left on his listing claiming that the product lit on fire and the customer was freaked out that the house could burn down.

Amazon has to take these issues seriously, and took down his listing.

Unfortunately, he didn’t have compliance documentation that was less than 2 years old, with the product testing that Amazon would accept.

In this series, I will break down the phases of the interaction with the client, what challenges they faced, and how we solved the problem for them.

When you’re trying to decide on who to work with when trying to solve problems with Amazon policy and compliance teams, it can be tempting to go cheap. Some issues, you can go cheap – and you will be fine. Some, if you go cheap, you are looking at weeks longer and potentially permanently closed listings.

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Rachel, I need your help!

I meet a lot of people at shows, through presentations, through interviews and meet-ups – and I’m always happy to provide my information. I’m easy to find on LinkedIn and Facebook, and am always happy to connect!

I got a message on Sunday, March 31st:

Hey Rachel, I need your help! Amazon is asking for safety test for our adapter. We have no ETL or UL. Is these what they want? or is there the other test you mentioned last year that can work?

Customer comment: “I received this product yesterday and when plugged in today the power supply exploded! Sparks shot out and the cover blew off! The device was not even on at the time it exploded! Fortunately we had just returned home or it could have been devastating.”

Here’s an example of the type of listing details that you might see on an adapter.

In this case, I advised that a UL listing, or ETL listing, would not be required. Amazon does not require an item be listed, as US law does not require listing. But, they do require safety testing to the standard, even if the item isn’t listed with a certification from a large testing lab.

Certification — the laboratory states that the factory, the design, and/or the components are safe, in all respects, for all production runs.

Laboratory test — the laboratory states that a specific item was tested to this particular standard and passed.

Amazon Product Safety is NOT Safety Policy

There are two safety teams at Amazon – one within the Product Compliance department, and one within Product Policy. Both look at customer complaints, but the Product Compliance team in general is more picky and more careful in their evaluation of documentation. You must be careful and focused when responding to issues with this team.

Their request:

Product Safety asks that you please respond to the above concern by taking the following steps:

  1. MOST IMPORTANT: Submit all relevant safety testing data and certification for the item. We ask you include testing specifically relating to the incident in question. Please refer to the attached word document of “Product Compliance Guidelines” if you have any questions. PLEASE NOTE: An MSDS does not suffice for safety testing.
  2. Complete the attached Product Safety Questionnaire. The questionnaire is geared towards addressing the safety concern that the customer has brought up. Please reach out to the manufacturer of the product for the details you might not have.
  3. Provide images of the product (front, back, accessories, and packaging). Images should include: model/serial number, safety/compliance marks & logos and safety labels & warnings on the product or packaging. Please also attach a copy of the instruction manual.

Thank you for your swift attention to this matter. We look forward to resolving this to our mutual customer’s satisfaction.

Please note:

While we investigate, product will remain unavailable for purchase from our website.

If the above documentation request is not completed in entirety within 7 days the case will be closed and the ASIN will remain suppressed.

${attachment-start}

To see the file named ‘Product Compliance Guidelines – ISO 17025.pdf,Product Safety Questionnaire – Electric Products.xlsx’ included with this correspondence, please use the Seller Central case link given below the signature.

${attachment-end}

Regards,

[First Name Last Initial]

Amazon.com Product Safety

How long does this take to handle?

what is the cheapest and fastest test that we can do that will satisfy this? is there a way to get the testing expedited? can you tell me what type/name of test we need?

I informed him that for this type of complaint, it would typically be a couple weeks at an accredited lab, and cost probably about $1200 to 2k in laboratory testing, and usually 2x the cost to expedite product testing.

The real challenge is that this was my old team at Amazon – and they don’t really have a sense of humor or willingness to compromise when there’s a claim of a fire. That’s a serious potential safety hazard.

My client was very frustrated about the timing, as the product does almost $50k in profit monthly.

Should you trust your supplier's feedback?

Unfortunately no, because they often know what retailers need from their previous experience, but Amazon is so confusing and variable that their advise is often unreliable for selling on Amazon.

my supplier asked the lab and they told her she needs either ETL or UL, and that these are the only safety US tests. But you say it can also be another test….I am trying to figure out from you what is thsi test…like how to describe it??

I responded that you can test first, and then submit to Amazon, and that certification is often not actually necessary.

What kind of costs can you expect?

If you’re working with us to get items tested prior to encountering issues with Amazon, then we can often coordinate testing and handle the discussions with the laboratory for only our hourly rate ($200/hr).

If you’re facing an imminent or actual shutdown, our fees start at $1247 and go up to $2247 for working with the lab, advising you on the right timing of each step, and making sure that your communication with Amazon is what is needed for the best possible outcome.

Laboratory testing starts at about $20/component for lead testing, up to thousands for complex electrical testing. We are careful to work with the laboratory to minimize your costs, and maximize the likelihood of success on the first try.

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Don't jump the gun!

I received this message on Tuesday, April 2nd:

I have sent the samples to the lab. They will arrive Friday china time. sf express [###].

Meantime, I could not wait and appealed with the FCC certificates I had. The POA is pretty strong I think. But if it fails, then doing the test with you is the plan.

I will keep you updated.

we sent 7 adapters and 7 [***]. My factory says that these [***] are never tested for ETL or UL since they are 12V only. I think the only question here is the adapter really.

she does not even know if the [***] itself can pass the ETL test as its not accepted in the industry to test them, but only the power source.

FCC stands for “Federal Comunications Commission” and is the agency that regulates communication devices…. not safety. All that an FCC certificate shows is that the device won’t interfere with other electronics or fry your brain with unsafe energy waves.

It’s not at all what Amazon is looking for… and worst of all, it makes it look like you not only don’t have the safety certification or testing you need, it looks like you’re ignorant of that fact as well.

When I managed the team, if I saw sellers respond in such a way, I assumed they were ignorant or trying to lie to us, and I would either mark them “do not reinstate” or I would ask them for safety documents on the rest of their catalog.

Thankfully for my client, his investigator was not quite so picky/thorough. However, the submission was of course rejected, and by the time the client received that information, it was 5 whole days later.

If he’d started with us on Sunday, we could have had testing documents in hand by the following Monday. Because he didn’t start until Thursday, the laboratory didn’t get back to us with final timing because that was their Friday.

Amazon's Response Comes Back

Amazon responded and specifically requested UL 60950 and testing on the product itself. They had only asked for testing on the adapter at first.

So again, be careful how you engage them – testing the adapter alone was definitely likely to be cheaper than what they were now requesting – the adapter plus the product itself.

But, the most frustrating part of this situation — the client’s account manager was able to get better information on what the product safety manager needed than the actual email they sent. Sometimes, communication with Amazon leaves a lot to be desired.

Now we're ready to get started

At this point, the client decided to move forward with us.

Making your payment now. But please be 100% transparent with me after that. I already spent money on consulting for this case elsewhere, and their solution is a test in USA which will take 2 weeks and cost much more than what you mentioned. So I am really hoping for a better solution with you.

As former safety managers at Amazon, we worked with global laboratories, we know what Amazon needs, and we used to have to work within a very frugal budget for Amazon’s own brands. We’re not just logging on to some lab’s website and getting you a quote – we’ve done literally dozens of these kinds of tests and appeals for our Amazon clients successfully.

Some can take longer than others, but as long as the client works with us, we can solve the problem for them. 

In Part II, I’ll talk about the process of working with the laboratory, their costs, challenges with time zone issues in getting responses, and getting the right reports in a way that Amazon can accept them.

If you’re not sure that you have the documents you need, you can work with us to get them — BEFORE a competitor takes down your listing for safety issues!
Trusted Expertise on Amazon
About the Author
I got my first job at Amazon because of my German language skills from my Master’s in History. Take that, people who said I’d never get a good job with my liberal arts degree! I soon learned that I’m not good at taking orders and started my MBA coursework at Seattle University.

I worked at Amazon for 8 years, as a liaison for law enforcement in Fraud/Transaction Risk, a quality and compliance manager in Product Compliance for Amazon Brands and imports globally, and lastly, managing hardware for Website Availability. I love the flexibility that working for clients on Amazon rather than for Amazon affords me.

In my not significant free time, I do fiber crafts such as spinning, crocheting, and embroidery, and I have been in a community band since 2009, playing French Horn, Trombone, or Euphonium depending on the band’s needs that season.

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