Listing products on Amazon typically requires a scannable GTIN barcode like UPC, EAN or ISBN. But for sellers of unique, handmade, or custom items, getting barcode numbers for every product isn’t always feasible.

This comprehensive guide covers multiple strategies for listing items on Amazon without GTIN/UPC codes including using FNSKUs, applying for exemptions, and working around restrictions.

Why Do Amazon Listings Require GTIN/UPC Barcodes?

Amazon wants every product listed in their catalog to have a corresponding GTIN like:

  • UPC (Universal Product Code) – 12-digit barcode commonly used in the United States and Canada
  • EAN (International Article Number) – 13-digit European version of UPC
  • ISBN (International Standard Book Number) – 10 or 13-digit code assigned to published books

These standardized product codes help identify and manage inventory. GTINs also enable commingling of products from multiple sellers into shared bins at Amazon warehouses.

Key benefits to Amazon from requiring GTIN barcodes on listings:

  • Accurate order fulfillment when products commingled
  • Ability to aggregate offers by treating identical UPCs as one product
  • Helps automatically match product data like details, pricing and imagery
  • Way to identify counterfeit items missing standardized identifiers
  • Data tracking and analytics on product performance

Amazon’s GTIN requirement isn’t meant to penalize sellers but to optimize their catalog and logistics at massive scale. But for small sellers, brands, artisans and authors, getting UPCs presents difficulties.

The good news is there are ways to list on Amazon without UPCs, which we’ll cover next.

How to List on Amazon Without a UPC

Here are several strategies sellers use to list products on Amazon without obtaining UPC barcodes:

1. Use FNSKUs Instead of UPCs

Apply a unique Amazon FNSKU sticker to products. Exempts items from needing a UPC.

2. Apply for a UPC Exemption

File a UPC waiver to list eligible products without a GTIN.

3. Use Amazon’s Seller SKU

Assign products a SKU identifier you create instead of UPC. Limits selling options.

4. Create Variation Listings

Add unbarcoded variations under a parent listing with a UPC.

5. Use Commingling SKUs

Leverage Amazon’s shared ASIN catalogue for commingled products.

Let’s explore the details, pros and cons of each approach:

1. Using FNSKUs to List Without UPCs

FNSKU stands for Fulfillment Network Stock Keeping Unit. It is a unique Amazon identifier assigned to products enrolled in Fulfillment by Amazon (FBA).

Here is how FNSKUs allow listing without UPCs:

  • FNSKU Format – 14 alphanumeric characters, like AB1289XZXCVB14
  • FNSKU Barcodes – Scannable and unique to each product
  • Auto-Exemption – Applying an FNSKU label exempts from UPC requirements
  • FNSKU Benefits – Allows FBA, commingling, tracking

To use FNSKUs:

  1. Create your product listing in Seller Central, leave a placeholder SKU
  2. Navigate to “Manage Inventory” then “Print Labels”
  3. Select “Generate FNSKU” – this assigns a unique FNSKU ID
  4. Print the label to apply to your product

FNSKUs essentially act as a substitute to UPCs, allowing sellers to list and sell products in FBA without needing barcodes.


  • Automatically exempts from UPCs
  • Lets you use FBA program
  • Simple labeling process


  • Only for products using FBA (no merchant fulfillment)
  • Need to apply FNSKU labels before shipping to Amazon warehouses

2. Applying for Amazon UPC Exemption

Certain product categories are eligible to receive exemption from Amazon’s UPC requirements. To receive exemption:

  1. Request exemption by emailing
  2. Provide info on product, category, reason for exemption
  3. Amazon reviews request and notifies if approved
  4. List products without UPC once approved

Categories Eligible for Exemption

  • Arts, crafts, sewing, fabric, knitting, quilting
  • Collectibles like trading cards, stamps, coins
  • Drones and RC vehicles
  • DVDs and CDs – must include original artwork
  • Gift sets – if all components individually exempted
  • Single game downloads/streams
  • Custom or handmade products
  • Products received direct from manufacturers
  • Self-published books


  • Can sell products without UPC or other GTIN
  • No specific labeling requirements


  • Exemption approval not guaranteed
  • Some categories like grocery, electronics ineligible
  • No option for commingling inventory
  • Listings may be restricted in some features

UPC exemption provides the most flexibility but requires application justification and Amazon approval.

3. Using Amazon Seller SKUs

Sellers can create their own unique SKUs to identify products instead of UPCs or FNSKUs using the “Seller SKU” field when creating listings.

However, listings without GTINs face restrictions:

  • Cannot sell through FBA – must be merchant fulfilled
  • Not eligible for commingling
  • Limited advertising and promotion options
  • Lower visibility in search and “Buy Box”
  • Requires additional info like shipping weight and dimensions

Seller SKUs allow basic listing without UPCs, but limit selling options. Should be used temporarily until obtaining exemption or product identifiers.

4. Creating Variation Listings Under Parent

For standalone items, this involves:

  • Obtain single UPC for main product listing
  • Create additional child variation listings without UPCs under parent
  • Add info differentiating variations like color, size, scent etc.

So parent listing would be general product. Child variations cover specific options lacking UPC.


  • Only need one UPC for parent
  • Can add multiple unique child listings


  • Parent and variants must be complementary products
  • Limits quantity of distinct items
  • Child variations may have lower visibility

Variation listings work for common offshoots from a main product. But limited for sellers with diverse catalogues.

5. Using Amazon’s Commingling Program

Amazon’s commingling program allows inventory from multiple sellers to be stored together under a shared ASIN product listing.

To use commingling:

  • Find the shared ASIN listing that matches your product
  • Confirm listing follows Amazon’s detail requirements
  • Ship units to Amazon under that ASIN for storage
  • Units will be collectively stored and sold drawing from shared pool


  • No UPC or unique identifier needed
  • Inventory is eligible for Prime


  • Very limited control over listing details
  • Issues with product condition, counterfeits, defects

Commingling functions best for stable commodity type products where individual units are interchangeable.

Getting a UPC Exemption from Amazon

Since UPC exemptions provide the most flexibility, here are tips for successfully applying:

  • Provide as much detail on the product as possible – category, materials used, production process etc.
  • Emphasize the handmade or specialty nature – include photos of the creation process if applicable.
  • Note that the items are one-of-a-kind products that lack manufacturer barcodes.
  • Include specifics on production volume – i.e. “150 customized paintings per year”.
  • Mention the use of your own branding, designs and packaging.
  • Highlight if you are the inventor, designer, author or artist behind the items.
  • If books, clarify if self-publishing and ineligible for an ISBN.
  • Note how exemption helps you listed much-needed income through sales.

The more details provided, the better chance of exemption approval. Well-crafted justification detailing the unique, unbarcoded nature of products gives Amazon necessary info to review.

Sourcing UPC and GTIN Barcodes

While exemptions, FNSKUs and workarounds help list on Amazon without UPCs initially, obtaining barcodes long term provides more sales options.

Sources to acquire UPC and GTIN barcodes:

  • GS1 US – Primary UPC provider in USA. $250 one time fee + $50 annual renewal. Assigns range of 1000 codes. Can only buy codes in your business name.
  • Hibu – UPC provider focused on small businesses. Packages start at $75 for single code, or $150 for 10 codes + subscription.
  • Nationwide Barcode – Retail barcodes starting at $45 per year for single code. Volume discounts available.
  • eBay – Can purchase individual 12-digit UPC codes for as little as $3-5 on eBay from various sellers. Limited legality.
  • Manufacturer – If ordering branded products from a factory, request they provide industry standard UPC codes on packaging/labels.

Purchasing 1-10 UPC codes from a lower priced provider can work temporarily. But for larger product catalogs, a GS1 prefix for unlimited UPC assignment may better suit long term needs.

UPCs for Amazon FBA vs Seller Fulfilled Items

Whether you need UPCs or can exempt depends partially on whether using Fulfillment By Amazon (FBA) or selling merchant fulfilled:

FBA Inventory

  • Requires FNSKU or UPC exemption
  • FNSKUs can substitute for UPCs

Seller Fulfilled Items

  • Requires UPC, exemption, or selling with limitations using Seller SKU
  • No FNSKU option since FBA not used

Due to FBA’s added barcode requirements, selling FBA eliminates the need for UPCs specifically by using FNSKUs instead.

But for merchant fulfilled sales, individual UPCs or an exemption ultimately become necessary to list without restrictions.

Pros and Cons of Commingling Inventory on Amazon

Commingling – where products from multiple sellers are grouped together under one listing – simplifies listing but has tradeoffs:


  • No UPC needed to list under shared ASIN
  • Items become eligible for Prime shipping
  • Easy to list and start selling quickly


  • Little control over listing details
  • Customer issues affect all sellers
  • Risk of counterfeits and product condition issues
  • Attribution errors on reviews and negative feedback

Ideal for: Commodity-type products like food, vitamins, basic electronics.

Not ideal for: Unique items, collectibles, valuables, fragile goods.

Commingling functions best for interchangeable commodities where specific item flaws, fakes, or mixups won’t destroy value. The risks outweigh benefits for most other products.

Amazon UPC Listing Requirements Summary

In summary, main ways to meet Amazon’s GTIN/UPC listing requirements:

  • Exemption – Request waiver approval for unique / handmade goods. Most flexibility.
  • FNSKU – Substitute for UPCs on FBA inventory. Labels easily generated.
  • UPC Barcode – Obtain UPC number from GS1 or other provider. Most universal.
  • Seller SKU – Sell without UPC but limited. Temporary option only.
  • Child Variations – Single parent UPC, multiple child variations.
  • Commingling ASIN – Shared UPC-exempt listings. High risk of issues.

So while Amazon strongly prefers scannable UPC codes for most products, sellers have alternatives like FNSKUs and exemptions to list custom, handmade, and unique items profitably.

FAQs – Listing on Amazon Without a UPC

Does handmade jewelry need a UPC code to list on Amazon?

For handmade jewelry, you can either apply for Amazon’s UPC exemption or use FNSKU labels instead of UPC codes to list and sell your products. Most handmade sellers opt for FNSKUs due to the ease of labeling.

Can I use a UPC purchased on eBay to list products on Amazon?

Yes, you can purchase and use individual UPC codes from eBay resellers to list products on Amazon. However, some eBay sellers may re-use codes already in use causing listing issues down the road. When possible, try to obtain UPCs directly from certified providers like GS1 US instead.

Do ISBN book codes work as UPCs on Amazon?

No. While ISBN book codes are a type of GTIN, Amazon requires a 12-digit UPC barcode specifically to list books. Self-published books without ISBNs require either a UPC exemption or the use of Amazon’s Seller SKU workaround.

If I have a UPC exemption, do I need to include an FNSKU?

No, with a UPC exemption approved by Amazon, you do not need to also include an FNSKU label on your products. The exemption allows you to list and sell the products without any UPC, FNSKU or other GTIN.

Can I list homemade soaps on Amazon without a UPC?

Yes, you can request a UPC exemption for handmade soap products. Be sure to highlight details like your small production volumes and one-of-a-kind nature when applying for exemption.


The key takeaways around listing on Amazon without UPC barcodes:

  • Many unique, custom and handmade items legitimately lack UPCs
  • Exemptions, FNSKUs and other workarounds help list without UPCs
  • Thoroughly describe products and creation process when seeking exemptions
  • FNSKUs substitute for UPCs, but only for FBA inventory
  • Sourcing individual UPCs provides most sales flexibility long term
  • Research and weigh UPC listing options for your specific products

With the right approach, niche producers can successfully list a wide range of items on Amazon without access to industry-standard UPC barcodes. Use this guide to identify and leverage the ideal UPC workaround to unlock Amazon’s massive reach for your distinctive inventory.


  • Gio Watts

    Gio Watts brings over 10 years of digital marketing experience to his role as marketing manager at Walletminded. In his current position, Gio oversees brand marketing, campaign management, and audience growth initiatives. Prior to joining Walletminded, Gio held marketing roles at several ecommerce and SaaS startups, most recently serving as senior marketing manager at CloudTable Inc. There, he specialized in paid social advertising and content marketing. Gio holds a bachelor’s degree in business marketing from the University of Oregon. He is a certified content marketing specialist and frequently guest lectures at his alma mater. When he's not devising omni-channel marketing campaigns, you can find Gio coaching youth basketball and indulging his passion for live music.

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