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I've been having issues with getting a GTIN exemption for the 20-unit challenge
Amazon has implemented a new process for GTIN exemption
Amazon has made recent changes to the GTIN exemption process. They now ask for proof of the product (e.g.,. images of the product, packaging, branding etc.).
You can proceed with the either of the following recommendations:
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Omit the GTIN exemption and get the UPC code as you typically would for your first product
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Apply for GTIN exemption and follow the suggested steps by Amazon (this process is similar to how you would apply for Brand Registry so could be considered practice for this)