Amazon Account Reinstatement and Suspension Prevention

More Confusion About Using UPC Codes on

Last week’s blog post was full of bad news. Used media sellers can get suspended for inauthentic claims, UPC codes that don’t match the brand will be flagged for inauthentic – a huge source of heartburn for those who make product bundles or who use their own UPC codes for branded products that seemingly don’t have UPC codes. This week I tried to get some clarification from Amazon and other sources. Here’s my answers to your questions.

Q. Does Amazon Want us to Buy Our UPC Codes from GS1?

Yes. They recommend it. But, to be clear, these are UPC codes for YOUR BRANDED PRODUCTS. In other words, if you are selling Cynthia’s Amazing Birthday Boxes which has toys and candies in it, you should register your brand and then buy a GS1 UPC code for it. If you are selling a FROZEN® bundle of beauty products, then you CAN’T do that. You are not Disney and you do not have the right to license their products or bundle them without permission.

In this way, we are different from most retailers. A brick and mortar store can easily take a bunch of branded items and put them into a cute container and sell them to you as a special deal (buy a towel, get a free washcloth and rubber ducky!). If they need a code for the check-out kid to scan, they use an internal code system. The GS1 is a huge database that uniquely identifies your brand in the global supply chain. If you don’t own a brand, you don’t use their codes. It is as simple as that.

If you are a private label seller, then getting a GS1 extension definitely makes sense – although it is not required – because it will be easier for Amazon to help you defend your listings for those who might create bundles or offer for sale your products in some unauthorized way. You can prove you own the GS1 for your brand and Amazon can easily confirm it.

Q. What if I Already Have UPC Codes from Somewhere Else?

Those UPC codes should still be OK as long as you are using them for your own unique bundles and NOT someone else’s brand. What Amazon is doing is checking all UPC codes against the GS1 database. Their concern is for brands. So if you are selling a Disney bundle without a Disney UPC extension and/or code, then they will shut you down because your code is invalid. If you are selling your own brand using a UPC code purchased elsewhere, that’s OK.

Q. What is the GS1? Does it Give Us Authorized UPC Codes?

Not exactly. GS1 is three things: 1) a huge database of branded product extensions (the unique digits that identify each brand) that you can search; 2) a system that helps you generate and manage your own UPC codes; and 3) an annual subscription for as long as you want your brands in their database.

Think about it this way, if you want to be able to generate and manage 100-100,000 UPC codes (like many apparel companies with all their size and color variations for example), you don’t want to buy someone else’s UPC codes, you want to manage your own. You can make the numbers actually mean something internally rather than being random. You can tell immediately what the item is just from the numbers in the UPC code. In addition, you can track where it came from and when – critical to food manufacturers who have to be able to instantly recall tainted food or drug manufacturers with tampering scares. The GS1 also provides proof of brand ownership and makes it easy to tell if someone has added their own UPC code to your brand…which is what Amazon is doing now.

Q. If I’m Able to Buy a UPC Code with the Same Extension as the Brand I Want Is That OK?

Absolutely not! It is not only illegal, Amazon would likely ban you from the platform without an appeal. Then you would have to deal with the brand’s lawyers. And to the person who asked me how Amazon would find out (c’mon! really?!), you need to know that the big brands have given Amazon a full list of their UPC codes and continue to do so as they add new products. Amazon is not just checking their extensions. See answer below for many of these brands (not necessarily comprehensive).

Q. Does This Mean We Can’t Create Bundles from Others’ Branded Products?

Yes…and not exactly. If you read one part of SellerCentral, it makes it sound like it is fine to create bundles and use your own UPC codes. If you read another part, it indicates that your bundles may be closed by Amazon as inauthentic. Here is the difference. You can create bundles, but NOT branded bundles (unless you own that brand). So if you want to put together some cute Disney bath items you can, BUT you can’t call it a Disney bundle. It would be: Bundle: Shampoo, Conditioner, Bath Poof, Princess-themed. In the DESCRIPTION for the bundle you can mention that it is Disney Princess® Shampoo, conditioner, etc. But not in the title. In addition, you would NOT put Disney as the manufacturer. You are the manufacturer. Put your brand: Cynthia’s Amazing Bathing Supplies. Attach your UPC code that you bought from GS1.

Q. Can We Get an Exemption from Needing a UPC Code?

Yes. You can get exemptions in certain situations. If your bundle is eligible for an exemption, then you don’t need a UPC code. The trick is to get the exemption first before making a bundle or listing a product. PS. A GTIN is a Global Trade Item Number which includes UPCs, ISBN, EAN and other product identification numbers (because UPC wasn’t enough of an acronym…).

Eligible cases for GTIN exemption

  • Brand, manufacturer or publisher does not provide a GTIN for the products. For example, private label products, or hand-made products
  • Non-branded products that do not have GTINs. For example, wholesale products
  • Parts do not have a GTIN. For example, some automotive parts do not have a GTIN
  • Bundles that do not have a GTIN. For example, customized bundles may not have a GTIN. So if your bundle has a customized element like a person’s name, then you can possibly get an exemption. To create bundles correctly, see Product Bundling Policy before requesting for a GTIN Exemption

Q. How Do I Get an Exemption?

You need to prepare your case for Amazon. You will need:

  1. A support letter from the brand owner, manufacturer or publisher to prove that they do not provide a GTIN for the products or a list of sample products for Amazon to review. The letter has to have the issuer’s name and contact information and state explicitly that they do not provide a GTIN for all the products that you sell. It must include your physical address, phone number, email or website address. It must be in English or the marketplace’s local language.
  2. A website link to view the products. If there is no website, upload pictures to an online image service or Snagit or Google Docs with a link.

Here’s a link to a template Amazon recommends for the support letter:

If you can’t get a support letter, you should submit a list of sample products for them to review using this template. Please note that if your bundles consist of products from the same brand, then use this template. If they are non-branded products, use this template:

Then you apply here.

We’re saved! Bundles galore! Oh wait, it surely isn’t that easy is it? Nope. Because some brands require a GTIN to list. No exemptions. Any ASIN that belongs to any of these brands and does not have a GTIN will be suppressed.

Q. Does Amazon Give us the List of Branded Products that Require UPC Codes?

Yes. Glad you asked! If you desire a UPC exemption in a category, make sure the brand of the item is not included in one of the following lists of major brands that require a UPC. My assumption is that these are the brands that have given Amazon their complete lists of UPC codes, BUT I would not rely on it to be comprehensive. I’m sure new brands are being added every day:

Q. Disney is One of the Brands That Requires UPC Codes. Does This Mean I Can’t Create a Bundle with Disney Products?

You can create a bundle but you can’t list Disney as the manufacturer and you can’t mention them in the title. Preferably you would have your own brand of gift bundles and list it under that. See my answer above.

In food it is clear. I can create a box of goodies from a mixture of brands and brand/label the product as mine (Cynthia’s Excellent Nibblies). If I want to create a multipack of Jelly Belly’s, I can’t. Only the manufacturer can. If I want to private label the Jelly Belly’s and take a 10lb bag and break it out into 10 1-lb bags I can as long as it is follows the health laws and is a private label product. If I want a 3-pack of three different kinds of retail box Jelly Belly’s I can do that. Wait, did I say food was clear? Sigh.

You’ll notice that none of the lists Amazon gave us includes food. I suspect this is because their rules were already set a year ago under grocery category restrictions. You can create food gift boxes with branded items to your heart’s desire as long as the bundle is under your brand.

Q. I Have Lots of Bundled Products on Amazon. What Should I Do Now?

  1. Change the titles. Take out the name of the brands.
    Instead of “Disney Cars® Conditioner and Shampoo Bundle,” call it “Boys Conditioner and Shampoo Bundle.
  2. You can still name the brands in the listing details or keywords
  3. Change the brand name/manufacturer to your brand
  4. Brand your bundle. Cynthia’s Boys Bathtime Fun Pack ¬– Conditioner and Shampoo Bundle
  5. Or, take your listings down if you are worried about getting caught with an invalid UPC code.

Q. What if I Can’t Change the Listing?

If the listing was created by the brand and you just listed against it, you are fine. If this is a listing you created yourself, you can change it. If this is a listing created by another seller, you should be able to change it unless they brand registered it. In that case, they need to change it. You can check the UPC against the GS1 to see if it matches the brand. If it doesn’t, you may want to close your listing until things get sorted out or until you can create your own listing that complies with the new reality. Obviously, if the listing is already compliant you don’t need to worry about it.

Q. If I Can’t Use the Brand Name in My Listing, It Won’t Sell!

Not exactly a question, but my answer is to put the brands in your description or keywords and make sure you have awesome pictures that follow Amazon style guidelines. In this way, your picture will hopefully be enticing enough for a buyer to open your listing and see the details on your bundle. If your items have a particular scent or flavor, you may be able to use that in your title even if you can’t use the brand. Neutrogena Rainbath Pear and Green Tea Shower and Bath Gel is trademarked but “Bundle – Shower and Bath Gel plus Shampoo and Body Lotion in Pear and Green Tea Scent” isn’t. You’ll have Neutrogena in the description or keywords and the picture. It should sell. Naturally if someone else has a similar bundle and they have not converted their listing to comply they may be higher on the search page than you because their bundle is more relevant.

Only you can decide how much risk you can live with. Amazon WILL get around to every bundle eventually.

Q. Is There Some Way Around This so Amazon Won’t Catch Me?

Gaming the system will make it worse for everyone by forcing Amazon to crack down on the brand registry to make it harder to cheat. Stop thinking this way. Focus on how you can comply vs how to get around the rules.

Q. What are the Disadvantages to Creating Branded Bundles on Amazon?

  • You don’t own the bundle. If the Brand decides to sell on Amazon as a seller, they will automatically have control of YOUR listing. They can change it or take it down at will. Once brands realize this, many will become “sellers” on Amazon so they can take over listings they don’t like. Think about that. If Neutrogena starts to sell on Amazon? Say bye-bye to your bundle.
  • Amazon will catch you if the UPC code is invalid.

Q. Is There a Safe Way to Create Bundles on Amazon?

I can never use the word “safe” with Amazon, but it seems like you can protect yourself if you follow these rules:

  1. Don’t put brands in your titles unless you own the brand
  2. Create your own branded bundle: Cynthia’s Bathtime Fun Pack vs. Disney Cars® Conditioner & Shampoo Bundle
  3. Create a FREE bonus or FREE gift. i.e. Disney Cars Shampoo + FREE Conditioner. This allows you to use the manufacturer’s UPC for the shampoo and yet create a bundle. It is one way to avoid the issues with UPC codes. This loophole will probably be shut down eventually.

Q. Amazon Hasn’t Sent Me Any Notifications. Does That Mean My Bundles Are OK?

No. It just means it will take Amazon a while to catch everyone. I expect this to be a long process.

Q. Will Amazon Grant Amnesty to Sellers?

Hah ha ha ha ha ha ha! Thanks for the laugh. Probably not. They only do that when they feel that something is their fault. They never feel that.

Q. What About Bundles That Are Already Up There? Are They OK?

Not if they are using an inauthentic UPC code. It is just a matter of time. I strongly urge sellers to fix their bundle listings NOW. Let’s put it this way, this next week is your amnesty. Use it wisely.

Q. What if Amazon Suspends Me for My Bundles?

Call us. 972-432-6398. Http:// While it is no comfort to you today, your experience will help other sellers.

Last Word About UPC Codes…For Now

Use your common sense. If you are looking at a familiar brand and want to create a bundle with it, it is probably registered with the GS1. If it isn’t, you are OK for now…but what about tomorrow when that brand registers? It is safer to not use brand names in your bundles. You can check the GS1 database if you really want to, OR create bundles that don’t list the brand as the manufacturer and that aren’t listed in the title.

More About USED Items with Inauthentic Claims

Q. Is Amazon Requiring that we Prove Authenticity for ALL Items Whether NEW or USED?

Technically, they only require we prove authenticity for items where there has been an accusation of counterfeit or inauthenticity…which means, YES. If you can’t prove authenticity when they ask you, you’re in trouble. You can recover from it once (assuming you don’t have a lot of problems with authenticity already in your NEW items), but that’s it. After that, you can’t afford one more claim where you can’t prove where you bought it. Counterfeit is counterfeit, stolen is stolen.

Q. Will They Actually Suspend You for Inauthentic USED Media?

Yes. My client sold a USED CD that got him shut down. I know I already answered both these questions last time, but many sellers are staggering around like deer in a headlight right now and I’ve been asked several times if it is really true.

Q. I Have a Lot of USED Inventory at Amazon That I Bought at Book and Estate Sales. What Should I Do?

So do I. My client had to remove all of his. Some of it he is selling on eBay, etc. This is a risk assessment you have to take for yourself. You can sell out of what you have and don’t buy any more where you can’t get a detailed, printed receipt (no hand-written ones), you can get rid of everything, or you can play the odds. CDs, DVDs and video games are much more likely to be counterfeit/bootleg. There are also counterfeit textbooks.

Q. What About Collectibles Like Collectible Games and Toys?

I’ve not seen anyone suspended yet for inauthentic collectibles…but it could happen. As Amazon said to us “counterfeit is counterfeit, stolen is stolen.” If they have a reason to believe that your rare game from the 1950’s is a fake, you’re in trouble if you bought it at an estate sale. This is very upsetting to me. I have a LOT of collectible games and puzzles on Amazon that I bought at estate sales for cash. I’m leaving mine up there for now but I won’t buy any new ones.

Also, one thing I’ve seen with collectible games/toys that is already against policy but which I think will really get sellers in trouble now is when they substitute parts for games that are missing pieces. If you can’t find the original piece, DON’T substitute something similar from another game. That is against Amazon policy AND very likely to lead to claims of fake, inauthentic, missing pieces, incomplete, etc.

Q. What About Refurbs?

If you bought your refurbished item (here I am referencing factory refurbs, not YOU re-conditioning an item) from a legit source, you should have an invoice or receipt and be OK. If you didn’t buy from a retail store or direct from the manufacturer with a factory warranty, then you can’t list it as a refurb in the first place. It’s used but not a refurb. Secondly, if you can’t provide an invoice or receipt, you will be in trouble if it is questioned as inauthentic.

Last Word on USED Media…For Now

We’ve not gotten my client reinstated yet. This part of the story is still unknown. Amazon is dead set that the CD was a bootleg which means that it should have been obvious to my client when he bought it that this was not a legitimate CD. Possibly it was recorded in secret (a “Live!” performance). I don’t know. Counterfeit and Inauthentic claims are mostly about perception. The buyer thinks there is something wrong for a reason. Fix the reason and you’ll stop getting complaints. In the case of USED media buyers, we need to be very careful about what we buy that it looks legit and put stuff down that seems a bit “off” for any reason. Sometimes the claims come from the rights holder. They KNOW it is a fake but the seller may have been fooled. In the case of this CD, it is possible that the symphony KNOWS they never made a CD so it has to be counterfeit. In either case, you can’t argue with Amazon, you can only confess and repent. Put together a plan that tells Amazon how you will ensure it never happens again.

Springtime in New York…

My business partner Lesley Hensell and I will be in New York next week. I’m speaking at the Feedvisor conference, we’re working with some of our clients and we’re hosting a special event Wednesday night for our clients and friends of the company at the Reserve Cut Kosher restaurant in lower Manhattan – one of the best steakhouses in the city with fabulous atmosphere and great reviews. We are very excited to eat something extraordinary while in the Big Apple. If you are in the area I hope that you will join us! Please sign up now, we have to give the restaurant our final numbers by the end of the day Monday.

  • Stacy
    Posted at 09:03h, 24 May Reply


    I just wanted to offer this info. I have several bundles that sell very well, so I wanted to go in and change the titles, manufacturer and brand to remove any branding other than my own from those areas. When I went to change the brand, I got the following error:

    I substituted ‘Stacy’s Stellar Party Packs’ and ‘Spongebob’ for the actual names, but you’ll get the point. It seems that Amazon doesn’t want me to change the brand name of an established ASIN that is already recognized as a SpongeBob brand.

    I hate to close this listing and start over, as I have great reviews and momentum going, but I don’t know what else to do,being that it won’t let me change the brand.

    If anyone has successfully changed the brand of an existing product, I’d love any input on how you got around this.


    • Eleanor
      Posted at 00:28h, 25 May Reply

      Same thing happened to me. I was just going to post about this. I deleted old bundles I am not selling on anymore. But I couldn’t change the brand or manufacturer. So I am thinking it is best to just delete them and start over? I just want to make sure that the listings are really deleted.

    • Stacy
      Posted at 05:38h, 25 May Reply

      Strangely the error I pasted in seems to have disappeared! It read:

      Brand Name :
      The value ‘Stacy’s Stellar Party Packs’ specified cannot be used as it conflicts with the value SpongeBob’ for ASIN ‘${2}’ in the Amazon catalog. If this is ASIN ‘${2}’, update the value to match the ASIN data. If this is a different product, update identifying information (UPC/EAN/Part Number/etc.).

      • Lorraine
        Posted at 06:43h, 25 May Reply

        Stacy and Eleanor,
        I am following your messages because I am in the same boat!
        Stacy, on your bundles, I am assuming you are using upc codes from a reseller and not GS1? And, if I understand correctly, you only changed the brand name and left your existing upc code? And this did end up working???
        Thanks so much!

        • Stacy
          Posted at 09:14h, 26 May Reply


          I did use UPC codes from a reseller. A lot of my bundles were created a year ago, and at that time I thought it was OK to do so. Anyway, yes I went into my listing and tried to edit just the Title, Manufacturer and Brand and when I entered my brand name it gave me the error that I posted. It did not work. It would not let me change the brand.

          Using a new UPC would mean creating a new product, and I lose all of my reviews and traction. But, I guess that is what I will end up doing once my inventory runs out on those ASINs.


          • Lorraine
            Posted at 11:05h, 26 May

            Thank you for clarifying that! I have the same scenario as you do – many, many bundles that have been created over a long time that have been great replens for me. I have already been recalling some. I have been working on new bundle packaging this week and plan to buy the GS1 codes this week also. I see no way around it. I have been selling for almost 10 years and one thing I have learned… Amazon is always changing and I just have to accept the changes and move forward.
            Thank you again for answering my question. I truly appreciate it!

  • Martin
    Posted at 11:28h, 24 May Reply

    So informative!

    3 things come to my head reading this.

    1- Whats the difference between a Privet label and Brand? I understand Disney is a brand and and my thing I make in china and only sell on amazon is a PL. But there’s lots in between.

    2- Amazon will need to find a way to address listings for very cheap items, being sold by the brand as singles in B&M shops. It wont pay to sell those on amazon if not multi packed. I believe Amazon does want to offer every product.

    3- What do we do when a brand changes the packaging on an item, but keeps the UPC and item code the same. There is always a period of time, when you have 2 packaging’s and one ups in the market. Some will sell on the old listing the new package. Other’s where creating a new listing (with there own upc) so not to be called out for “Item not as described”.

  • Martin
    Posted at 15:33h, 24 May Reply

    I came across this listing when doing research. (I dont know anything about this seller )

    Is this allowed? Can you add an undefined item so you keep every one off listing? Can brand be AXE?

  • Scott
    Posted at 11:35h, 30 May Reply

    My understanding is that the new Amazon rule allows bundling of assorted branded items if:

    1. The actual brand(s) is not listed in the title
    2. The brand is entered as a name unique brand to the seller – a brand the seller makes up.
    3. The manufacturer is entered as a name unique to the seller as well.

    4. Unclear – using reseller UPC codes (not registered GS1 codes). It looks like others have successfully changed the required information and continued using reseller UPC codes originally assigned to the listing – but is it going to be accepted by Amazon – now or in the future? Will or does Amazon require GS1 codes for all branded bundles?
    5. Unclear – about what information gets entered in the manufacturer part number field.
    6. Unclear – about what information gets entered in the model number field.
    4. Unclear about what information gets entered in the manufacturer field as well.

    Just a thought Here:

    Wonder what the legal implications are in terms of restricting or even disallowing individual sellers the ability to resell “bundles” of items they purchased and are the legal owners of the items.

    Here in the States we have something called the “first sale doctrine.” It simply means that once a tangible copyrighted work (or something with copyright in it) is sold lawfully the first time, the original copyright owner no longer has rights over the physical item. After that, the buyer can do whatever he or she wants with it — sell it again, donate it, whatever. That’s why you can legally hold a yard sale or sell computers on eBay. The resale right applies only to the physical item sold, not copies.

    A U.S. Supreme Court decision in March of 2013 decided a case that reinforced the right to re-sell something that you had lawfully bought. If Amazon disallows sellers to resell bundles or makes it so difficult by requiring GS1 registration, it doesn’t seem right.

    • Cynthia Stine
      Posted at 15:25h, 24 January Reply

      Hi. First sale doctrine does NOT apply here because you are representing that your items are NEW and according to Amazon they are USED. If you were selling these items as USED, then no problem. However, Amazon only allows a few categories to sell USED. If you want to sell these items under the first sale doctrine, go to eBay. If you read the contract you signed with Amazon you will see that you have NO RIGHTS whatsoever when it comes to the platform. Amazon’s focus is a perfect buyer experience. Anything less is not tolerated. Sorry.

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    Posted at 10:53h, 01 June Reply

    […] More Confusion About Using UPC Codes on Decoding Amazon’s New Barcode Policy […]

  • William Shaker
    Posted at 09:29h, 03 June Reply

    Hi Cynthia,

    I have bought UPC codes for my private label product from eBay (the kind that is like .99 for 100) and now I want to buy a GS1 and convert it over. However, when editing the listing it says:

    Product ID : Editing this attribute can be potentially dangerous. Please edit with caution.

    What should I do?

    • Cynthia Stine
      Posted at 15:27h, 24 January Reply

      You may need Amazon’s help to do it. I’m not sure if they will allow you to do it yourself or not. Since you are the owner of the listing you SHOULD be able to, but I don’t know for sure.

  • Boris
    Posted at 11:50h, 04 June Reply


    When you are talking about selling under “your own brand” Cynthia, do you refer to Amazon seller name or own business name? I understand it should be one that you use for bundles and constantly so it sounds like seller name would do?

    – If we create a bundle with products of multiple brands, we must provide our own UPC from GS1 when we sell under our own brand (seller name) if Amazon somehow detects one of items have UPC?

    Comes kinda expensive as their prices start with 10 UPCs minium purchase and monthly subscription. I guess it does not make sense if you do not have suppliers to ensure consistent supply. Like doing RA/OA where you come upon bundle once in a while or by a chance. Otherwise it’s a thrown away UPC.

    Same question as above but if bundle has none of branded products that have their own UPC? Are we okay to use UPCs from resellers or request exemption? But what is the chance brands would allow that in letter to some Amazon seller? Former option of using UPCs from resellers sounds easier as we do not have to have letter from brands and upload documentation. Just avoid mentioning brand in title and bullets and in listing’s backend except keywords.

    Question about trick where you offer FREE gift for a bundle with branded product that already has UPC in catalog. I understood that we can use UPC of that brand for our bundle but isn’t the problem with that is going against product bundling policy point which mentions that UPC must be for entire bundle and not be taken from one of its products?

    Thanks for information!

    • Ecaterina
      Posted at 13:57h, 12 June Reply

      I’m going to start selling of the products with my private label. Could you provide me any information or link about requirements on the packaging with private label if the brand hasn’t still registrated on Amazon?
      And could we use stickers on the box with our private label and company information?
      Thanks in advance!

  • Doug
    Posted at 00:16h, 12 June Reply

    I think I am still a bit confused on the proper UPC codes to use as a private label seller who owns his brand. Is it still ok to use a UPC code purchased from the general services that sell UPC codes, or MUST you have a GS1 UPC code on our own branded private label products?

    • Cynthia Stine
      Posted at 15:21h, 24 January Reply

      It is OK to use UPC codes purchased from a cheapie UPC service for your REGISTERED private label products. However, be aware that most of those are recycled UPC codes. If someone else used it previously on the platform, you can’t. What you will want to do is get brand registered and then attach your listings (and UPC codes) to your brand registry. GS1 is affordable if you are buying multiple UPC codes. If you buy 100, for example, your cost per UPC code drops down to a couple of dollars. You will be registered in GS1, no one else will be able to use your UPC codes and the chance for confusion will be zero.

  • Shelaine
    Posted at 00:00h, 20 December Reply

    We manufactured a product and have UPCs. On Amazon, we got ASINs for the bundled product first (a few of two different flavours). But when it came to listing our individual products, they said it cannot be done because the UPC is used. We had two different flavours in our bundle/multipack. Why can’t we list the individual???

    • Cynthia Stine
      Posted at 15:09h, 24 January Reply

      You need a separate UPC code for each individual flavor as well as the multipack. When you bought your UPC codes did you buy them from GS1 or from a cheap UPC provider? If the latter, then your UPC code IS used. Those codes are cheap because they are recycled. If the UPC code is already on Amazon for another product, you can’t use it.

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