Core Reasons Why Amazon Requires FDA Registration
Amazon requires Taiwan cosmetics sellers to complete FDA registration for three main reasons: platform liability, consumer safety, and account compliance. After the MoCRA law goes into effect in 2023, Amazon, as an e-commerce platform in the U.S., may face liability and high fines if it sells cosmetics that are not FDA-registered. As a result, platforms are shifting compliance responsibility to sellers through mandatory registration policies, while protecting themselves from regulatory risk.
For Taiwanese sellers, this meansEven if the product complies with Taiwan regulations, if the FDA registration has not been completed, you may still face the risk of having your listing taken down, your account suspended, or even permanently blocked.This policy will not only affect new sellers, but also existing sellers. This policy not only affects new sellers, but also existing sellers who need to complete their registration documents by the deadline or they will not be able to continue selling.
For a more in-depth look at the impact of MoCRA regulations on the registration system, check out our FDA Cosmetic Registration System after MoCRA RegulationThe
Amazon Platform Policy Evolution and Regulatory Pressure
How MoCRA Regulations Change Amazon Policies
Passed at the end of 2022 MoCRA (Modernization of Cosmetics Act)For the first time, the registration and product listing of cosmetic facilities has been changed from "voluntary" to "mandatory". All responsible parties selling cosmetics in the U.S. must register by December 2023 or the sale will be considered illegal.
Amazon, one of the largest e-commerce platforms in the U.S., will begin requiring sellers to provide FDA registration numbers in phases starting in mid-2023 to avoid legal risks associated with the proliferation of non-compliant products on its platform. Initially, the notification will be "suggested", but from 2024 onwards, it will be gradually upgraded to a "mandatory requirement", and sellers who fail to do so will not be able to create new listings or reinstate products that have been taken off the market.
Amazon's Legal Risks
Under MoCRA, if a platform knows or should know that it is selling a product for which registration has not been completed, it may be considered to becommon violatorIn addition, they face the following consequences:
- FDA Warning Letters (Warning Letter): Require platforms to take down all unregistered products
- Civil penalties: Maximum fine of US$$100,000 per offending product
- Criminal Liability: Serious breaches may involve criminal proceedings
To avoid these risks, Amazon has chosen to shift the responsibility for compliance entirely to the seller, through a systematic review mechanism that ensures all cosmetics on the platform are FDA-registered.
Practical Implications for Taiwan Sellers
Account Risk and Sales Restrictions
Taiwanese sellers who have not completed FDA registration will face the following practical implications:
| Type of Impact | Concrete consequences | Time of occurrence |
|---|---|---|
| New products on the shelves are blocked | Unable to create a new listing in the Cosmetics category | immediate effect |
| Existing products removed from shelves | Sold products were marked as non-compliant and taken off the shelves. | 7-14 days after notification |
| Impaired account performance | Decline in account health due to accumulation of violations | Cumulative impact |
| Account Suspension | Multiple violations or failure to meet deadlines for improvement | 30-60 days later |
| Permanently blocked | Serious or Repeated Breaches | Depends on the occasion |
Clarification of Common Misconceptions
❌ Misunderstanding 1"My product is legally registered in Taiwan, Amazon should recognize it."
✅ correct solution (a math. equation)Taiwan Cosmetic Registration and U.S. FDA Registration are two separate systems, and Amazon only recognizes FDA registration numbers.
❌ Misunderstanding 2"I'm a small seller. Amazon won't check me out."
✅ correct solution (a math. equation)Amazon uses an automated system to check that all cosmetic listings are required to provide a registration number, regardless of size.
❌ Misunderstanding 3: "I can use another seller's registration number."
✅ correct solution (a math. equation)The registration number binds specific companies and products, and the use of other people's numbers will result in permanent blocking.
Figure 2: Amazon FDA Enrollment Review Flowchart

Description of the use of the picture::
This flowchart visualizes the steps Amazon takes to review a seller's FDA registration and helps Taiwanese sellers understand how the platform verifies compliance.
Response Strategies for Taiwan Sellers
Steps to Take Now
If you are a Taiwan Cosmetics seller, we recommend that you take the following steps immediately:
- Confirm whether the product belongs to the cosmetics category
Check that the product meets the FDA definition of cosmetic (cleaning, landscaping, improving appearance, etc. uses) - Determining the identity of the responsible party
Confirm whether your company is a Responsible Party or you need to designate a U.S. Responsible Party.
For detailed judgment criteria, please refer to What is the FDA's determination of who is responsible for cosmetics? - Appointment of U.S. Agent
If your company is located in Taiwan, you must designate a U.S. agent to assist with FDA communications. - Completion of FDA registration
- Facility Registration (FFR): registration of a manufacturing or packaging facility
- Product List (PLC): Register the recipe and labeling information for each product.
- Submit your number in the Amazon back office
Log in to Seller Central and upload your FFR and PLC numbers on the product page.
Time Planning Suggestions
| Stage | Estimated Time | Key Tasks |
|---|---|---|
| Preparation period | 1-2 weeks | Collect company documents, product formulas, labeling information |
| Registration Period | 2-3 weeks | Completion of FDA CFRPS system registration and serialization |
| Submission period | 1 week | Upload your number to Amazon backend and wait for review |
| Total | 4-6 weeks | Advice on planning ahead to avoid sales interruptions |
Figure 3: FDA Registration Readiness Checklist for Taiwan Sellers

Description of the use of the picture::
This checklist organizes the FDA registration preparations that Taiwanese sellers must complete before selling cosmetics on Amazon to avoid account risks.
3 Key Points for Special Attention
1. registration numbers may not be shared or forged
Each FDA registration number is tied to a specific company and product formulation. If you use another person's number or forge a number, Amazon's system automatically detects and seals the number immediately, and the record of the violation is permanently retained, jeopardizing future complaints.
⚠️ important reminderAmazon regularly matches the FDA database to ensure the authenticity of the number. Even if a product is cleared in the short term, it may still be penalized retroactively.
2. existing products are also required to be registered
Even if a product has been sold on Amazon for many years, as long as it is in the Cosmetics category, it must have an FDA registration number within the platform's notification period. Failure to do so will result in the product being automatically removed from the market and cannot be restored.
3. Different brands need to be registered separately
If you sell multiple brands of cosmetics on Amazon, each brand requires a separate FDA registration. Products from different brands cannot share the same registration number.
Conclusion
- Amazon Requires FDA Registration Based on Legal Liability and Platform Risk ManagementThe Government is not a mere administrative requirement.
- Taiwan sellers must complete the Facility Registration (FFR) and Product Listing (PLC).How to sell cosmetics legally on Amazon
- Failure to complete registration will result in the removal of the product from the shelves, suspension of the account, or even permanent banning of the account.Risks
- It is recommended to start preparation 4-6 weeks in advanceTo avoid sales disruption affecting results
- The registration number cannot be shared or forged.Violations will result in permanent banning of your account.
If you still have questions about the Amazon FDA Cosmetics registration process, please refer to Green Circle Official Website professional consulting services, or read our FDA Cosmetic Compliance Map: From Registration to MarketingThe first step in the process is to understand the full compliance steps.
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