When you create your first product on Amazon you run into a mandatory field: the GTIN (the number behind an EAN or UPC barcode). If you don't fill it in, you can't publish. But there is a way to sell without that code: the GTIN exemption. In this guide we explain exactly what it is, who can request it, how to apply step by step and, above all, when the exemption is worth it and when buying a code is faster and safer.
In short
- The GTIN exemption is a permission from Amazon to publish a product without a barcode: Amazon assigns it an ASIN based on the brand and the data, with no EAN or UPC needed.
- It's not for everyone: it only applies to own brands, generic unbranded products, parts and spares, or bundles you create. If you resell products from other brands, Amazon will require the manufacturer's GTIN.
- An own brand almost always requires Amazon Brand Registry, which in turn requires a registered trademark (a process of several months and hundreds of euros at the trademark office).
- The turnaround ranges from a few hours to several days and the request can be denied over the photos (visible brand, low quality) or the category. Buying an EAN-13 is immediate.
- The exemption only works within Amazon: on eBay, Shopify, AliExpress or Google Shopping you'll still be asked for your own barcode.
- If you don't have a registered trademark or you want to sell today, buying an official EAN-13 from €3.98 is usually faster and cheaper than fighting for the exemption.
What is the Amazon GTIN exemption?
The GTIN exemption is a permission granted by Amazon to publish a product without entering a barcode. Instead of the GTIN, Amazon internally assigns an identifier (ASIN) based on the brand and the product data. It's designed for cases where the product, legitimately, does not and cannot have an official barcode: handmade products without a registered trademark, spare parts, bundles or certain own-brand items.
It's important to understand that the exemption is not a universal shortcut: Amazon reviews it case by case, may ask you for photographs and documentation, and denies it if it believes the product should carry a GTIN. That's why, for many sellers, getting the exemption ends up being slower than buying an EAN and starting to sell the same day.
Who can request the GTIN exemption?
Amazon mainly allows the exemption in these situations:
- Own brand without barcodes. You manufacture or sell under your own brand and haven't purchased GTINs for your products. This usually requires being enrolled in Amazon Brand Registry.
- Unbranded (generic) products. Items sold as "generic" with no associated branded manufacturer.
- Parts and spares. Replacement parts for automotive, electronics or machinery that the manufacturer does not identify with a GTIN.
- Packs or bundles you create. You combine several products into a new lot that doesn't exist as such in any database.
If your case doesn't fit any of these — for example, you resell products from other brands — Amazon will normally require the manufacturer's GTIN or a valid code.
Eligibility also depends on the category. Amazon is more flexible with categories such as Handmade, clothing, jewellery, automotive spares or unbranded products, and far stricter with "gated" or high-risk categories (cosmetics, supplements, consumer electronics, toys), where it often won't grant the exemption even if the brand is yours. That's why the real first step isn't preparing photos, but checking the eligibility of your specific category + brand combination in Seller Central before investing any time.
How to request the GTIN exemption step by step
The process is done from Seller Central and, broadly speaking, works like this:
- Go to Seller Central → Catalogue → Apply for a GTIN exemption.
- Select the product category and enter the brand name (or "Generic" if it has no brand).
- Click Check eligibility. Amazon will tell you whether that combination of category and brand can qualify for the exemption.
- Upload the evidence it asks for: usually between 2 and 9 images of the product and its packaging from several angles, showing (or showing the absence of) the brand and code. Sometimes they ask for a letter from the manufacturer.
- Submit the request and wait for the review. The response usually takes from a few hours to several days.
- If it's granted, you can now create the listing without a GTIN. If it's denied, you'll have to correct the evidence or use a barcode.
The point that sinks the most requests is the images. Amazon expects real photos of the product and its packaging (not renders or mock-ups), sharp, well lit and, unless told otherwise, against a white background. For an own brand, the brand must be visible printed or labelled on the product or packaging; for generic products, it must be clear that there is no visible brand or barcode. Upload views from several angles (front, back, side, label) and, if Amazon asks for it, a letter from the manufacturer on headed paper confirming the product has no GTIN. A single blurry photo, or one with someone else's logo peeking in, is usually enough for a denial.
Brand Registry and registered trademark: the requirement that holds people back most
For own-brand products, the exemption is almost always tied to Amazon Brand Registry, the programme that protects your brand within the marketplace. And here's the bottleneck: to join Brand Registry you need, in most countries, a registered trademark at the relevant trademark office (the EUIPO for an EU trademark, the OEPM in Spain, the USPTO in the United States).
That's no trivial process. Registering an EU trademark with the EUIPO costs from €850 for one class and usually takes 4 to 6 months if no one opposes it. The OEPM in Spain starts at around €125 per class but also takes months. While the trademark is only "applied for" and not yet granted, Brand Registry won't admit you, and without Brand Registry the exemption for an own brand normally won't move forward. For a seller who wants to launch their first product this week, that timeline makes the exemption route unworkable.
Case studies: when it fits and when it doesn't
Three real-world situations to see the difference:
- Maker selling soy candles without a registered trademark. She sells in the Handmade category, with no logo. The exemption as "Generic" is usually granted quickly and saves her the code: here the exemption makes complete sense.
- Entrepreneur with own-brand supplements. He has a logo but the brand isn't registered yet. He can't join Brand Registry, the category is strict and the exemption is denied. He's better off buying an EAN and publishing while the trademark is being processed.
- Shop creating a bundle of 3 different mugs. The bundle doesn't exist in any database. They can request an exemption for that specific bundle, but since they also want to sell it on their Shopify, it suits them better to assign it their own EAN-13 that works across all channels.
Limitations and common problems with the exemption
The exemption sounds good on paper, but in practice it causes plenty of headaches. These are the problems sellers report most often:
- Denials over the photos. If Amazon detects a visible brand, or the images aren't sharp or on a white background, it rejects the request.
- Brand Registry requirement. For an own brand, you often need to have the trademark registered (a process that costs money and months), which makes it unfeasible for someone just starting out.
- It only covers that channel. The exemption works for Amazon; if tomorrow you want to sell on eBay, AliExpress or Shopify, those sites will still ask you for a barcode.
- Wasted time. Between preparing photos, checking eligibility and waiting for reviews, it can take you days to start selling.
GTIN exemption or buying an EAN code: which is best for you?
There's no single answer, but this table helps you decide quickly:
| GTIN exemption | Buying an EAN | |
|---|---|---|
| Cost | Free (but with requirements) | From €3.98 · one-off payment |
| Time until you can publish | From hours to days | Immediate (minutes) |
| Requires Brand Registry | Often yes | No |
| Works outside Amazon | No | Yes (eBay, Shopify, Google…) |
| Risk of denial | Yes (photos, brand) | No |
In short: if you have a registered trademark and you're only going to sell on Amazon, the exemption can save you the cost of the code. If you don't yet have your trademark registered, want to publish today or plan to sell on other marketplaces too, buying an EAN-13 is usually the fastest and cheapest option: for a few euros, a one-off payment with no annual fees, you skip the whole exemption process.
Let's do the maths honestly. The exemption is "free" only if you already meet the requirements: if you have to register a trademark to get it, we're talking about hundreds of euros and several months, versus the €3.98 and the few minutes an EAN-13 costs. Even when you do meet the requirements, the hidden cost is time: preparing the photos, checking eligibility by category, waiting for reviews and, if you're denied, repeating the cycle. That's why many sellers who could request the exemption end up buying the code anyway, because it works out cheaper in hours of work. The exemption shines in one specific scenario — a trademark already registered, a single flexible category, exclusive selling on Amazon — but outside of that, the EAN almost always wins.
And there's a strategic nuance: an EAN-13 gives you a unique, permanent identifier that travels with you to any marketplace, search engine or catalogue. The exemption, by contrast, ties you to Amazon. If your plan is to grow and sell across several channels, the code is an investment you don't have to repeat.
Reminder: which code Amazon asks for
When you don't use the exemption, Amazon accepts as a GTIN either an EAN-13 (the standard in Europe, 13 digits) or a UPC-A (12 digits, common in the US). Both are official codes issued from the GS1 database. You can check whether a code is valid with our free EAN-13 verifier before uploading it. If you want to dig deeper, we have a complete guide on barcodes for Amazon and another on how to upload products to Amazon with your EAN.
Frequently asked questions
Is the GTIN exemption free?
Yes, requesting it is free. But it often requires having your trademark registered (Brand Registry), which does cost money and time, and it can be denied.
Can I sell on Amazon without a barcode?
Yes, if Amazon grants you the GTIN exemption for that category and brand. If it isn't granted, you'll need a valid EAN or UPC.
How long does Amazon take to approve the exemption?
It depends on the case: from a few hours to several days, and it may ask you for more evidence along the way. Buying an EAN is immediate.
Does the exemption work for selling on other sites?
No. It only applies to Amazon. For eBay, AliExpress, Shopify or Google Shopping you'll need your own barcode.
Do I need a registered trademark to request the exemption?
For own-brand products, almost always yes: the exemption usually requires being in Amazon Brand Registry, and Brand Registry requires a trademark registered at the trademark office (EUIPO, OEPM, USPTO…). For generic or unbranded products it isn't necessary, but then no logo can appear in the photos.
Why does Amazon deny my exemption request?
The most common reasons are low-quality photos or photos with a visible brand that isn't yours, a category that doesn't allow the exemption, a missing letter from the manufacturer, or a trademark that isn't really registered. Fix that evidence and try again, or use an EAN so you don't depend on the review.
Does the exemption work for every Amazon category?
No. Amazon is flexible with Handmade, clothing, spares or generics, but usually refuses it in sensitive or restricted categories such as cosmetics, supplements, toys or electronics. Check the eligibility of your category and brand before preparing anything.
Is it legal to use an EAN bought from a reseller on Amazon?
Yes, as long as it's an official EAN-13 issued from the GS1 database. Bear in mind that for Amazon Brand Registry or large retailers that require the code to be bought directly from GS1 under your brand's name, it's worth checking first.
Start selling today
If the exemption is getting complicated or you simply want to publish now, buying your code takes just minutes. At EAN CODA we sell official EAN-13 codes with a one-off payment, no annual fees and immediate delivery by email. Get your EAN code from €3.98 and upload your product to Amazon today.