Is an expired COA the same as a failed COA?

No. A failed COA shows a result outside specification, so the product is the problem. An aged-out COA may show a product that would pass every specification; it's simply too old to accept as current evidence. The fix differs: reformulation for a failure, a fresh test for age.

Does an aged-out COA mean my listing gets suspended immediately?

Not immediately, but it removes your ability to pass a review when Amazon asks for one. Listing suspensions over documentation typically follow a request for evidence that the seller cannot currently satisfy, and an aged-out COA is exactly that situation waiting to happen, not an automatic trigger by itself.

Why does the same document age out for Amazon but not for FDA?

Because the age limit is TIC-provider policy, not FDA regulation. 21 CFR Part 111 sets no expiry on a COA. Amazon's approved providers enforce a document-age window as part of their own acceptance criteria for verification, independent of what the regulation requires.

What does it cost to fix an aged-out COA?

Inside the window, a TIC provider review of an existing COA runs roughly $80 to $120 per product from published price sheets. Outside it, fresh testing to produce a new COA runs roughly $500 to $1,000 per product: the cost of being a few days late, multiplied across however many SKUs aged out at once.

What is the 60/30/14 approach?

Treating 60, 30, and 14 days before a COA ages out as three separate checkpoints, each with a different action (confirm the next lot is coming at 60, request the document at 30, treat it as urgent at 14) rather than waiting for a single deadline and finding out too late.

Guide

What happens when a supplement's Certificate of Analysis expires?

By Jake, founder · Published 2026-08-17 · Updated 2026-08-17

Nothing happens to the document itself; it doesn't become false. What changes is that an Amazon-approved TIC provider will no longer review it. Past the document-age window, a submission built on that COA is rejected, and the only way back is a new COA, usually meaning fresh testing rather than a review of paperwork already in hand.

The document doesn't change; its usability does

A Certificate of Analysis records what a lab found in a specific sample on a specific date. That record doesn't become inaccurate as time passes. What changes is whether an Amazon-approved TIC provider will still accept it as current evidence: the providers who perform verification apply a document-age window, and a COA older than that window is not reviewed, regardless of what its results say. The strictest published figure is 182 days from the certificate's own date. Why the figure is a provider policy rather than a regulation, and why sources disagree on the exact number, is covered in how long a COA is valid for Amazon, which this article assumes as background.

Document-age window applied here: 182 days, the strictest reported value; other sources report 274 and 365 days. Last verified 2026-07-24. This is provider policy, not regulation, so confirm the current figure with your TIC provider before relying on it.

The chain, step by step

From an aging COA to listing risk
Stage	What's happening	What it means for the seller
Inside the window	The COA is current. A TIC provider can review it directly.	Verification is a document review, roughly $80 to $120 per product.
Window closes	The certificate date passes the document-age cutoff.	The same document is no longer eligible for review, and nothing about the product changed.
Review becomes impossible	A submission built on the aged-out COA is rejected by the TIC provider.	The seller cannot pass verification with documents currently on hand.
Retest required	The only route back is a current COA, which for a non-manufacturing brand means commissioning new testing.	Cost rises to roughly $500 to $1,000 per product, and there's a lab turnaround wait before a new document even exists.
Listing risk	If Amazon requests evidence during the wait, or a scheduled re-verification comes due, the seller has no current document to offer.	The practical exposure is the listing itself, on the category or platform requiring verification.

Cost figures last verified 2026-07-24, from published TIC provider and third-party laboratory price sheets. They are configuration, not constants: providers change their pricing.

Why "listing risk" and not "listing suspended"

An aged-out COA is a precondition for a suspension, not the suspension itself. Amazon's verification requirement is enforced when a TIC provider is asked to confirm a product: at onboarding, at a scheduled re-verification, or when Amazon flags a listing for review. An aged-out COA only becomes a problem at the moment evidence is actually requested. The risk is real precisely because that moment is not fully within a seller's control: a brand that let every COA lapse learns about it when a review is already underway, not on a schedule of its own choosing. What documentation-triggered suspensions look like in practice is covered in listing suspended over documentation.

The 60/30/14 approach

Rather than tracking one expiry date per SKU and reacting when it arrives, treat the run-up to that date as three checkpoints, each with a different job:

60 days out, renewal season. Confirm whether the manufacturer's next production lot is coming soon enough that its COA will simply replace the current one before the window closes. If so, there may be nothing to do but confirm the timeline.
30 days out, request the document. If no new lot is imminent, this is the point to request a COA for the current lot from the manufacturer or lab, while there is still enough runway for normal turnaround.
14 days out, treat it as urgent. A verification started this close to the cutoff may finish after the document ages out. This is the point where the cost is effectively already the retest price, not the review price, so act accordingly rather than waiting to confirm.

Compliant Always sends these three warnings automatically on paid plans and shows the next expiry, with its cost, on the readiness page on every plan: the same checkpoints described here, not a separate schedule.

What doesn't reset the clock

A new label or listing update on the same product. The clock runs from the certificate's date, not the listing's.
A manufacturer re-issuing the same certificate with a new cover page. Reviewers read the sample date and report date on the certificate itself, not the date it was resent.
Passing a review once. Each verification cycle checks the document that's current at that time, not a permanent status on the product.

Related: what a reviewer looks for on the document itself is in how to read a Certificate of Analysis, and what counts as evidence for a specific lot versus a product generally is in do I need a COA for every lot. Run the free check to see today's days-remaining number for every SKU you upload, not just the ones you remember to watch.

Sources

Document-age window and cost figures, operational configuration, verified 2026-07-24 accessed 2026-08-17
eCFR, 21 CFR Part 111, Subpart E (no COA expiry is set in regulation; the age window is TIC-provider policy) accessed 2026-08-17
SGS, Amazon Verification for Dietary Supplements (each product verified annually per ASIN, independent of the certificate's own age window) accessed 2026-08-17

Frequently asked questions

Is an expired COA the same as a failed COA?: No. A failed COA shows a result outside specification, so the product is the problem. An aged-out COA may show a product that would pass every specification; it's simply too old to accept as current evidence. The fix differs: reformulation for a failure, a fresh test for age.
Does an aged-out COA mean my listing gets suspended immediately?: Not immediately, but it removes your ability to pass a review when Amazon asks for one. Listing suspensions over documentation typically follow a request for evidence that the seller cannot currently satisfy, and an aged-out COA is exactly that situation waiting to happen, not an automatic trigger by itself.
Why does the same document age out for Amazon but not for FDA?: Because the age limit is TIC-provider policy, not FDA regulation. 21 CFR Part 111 sets no expiry on a COA. Amazon's approved providers enforce a document-age window as part of their own acceptance criteria for verification, independent of what the regulation requires.
What does it cost to fix an aged-out COA?: Inside the window, a TIC provider review of an existing COA runs roughly $80 to $120 per product from published price sheets. Outside it, fresh testing to produce a new COA runs roughly $500 to $1,000 per product: the cost of being a few days late, multiplied across however many SKUs aged out at once.
What is the 60/30/14 approach?: Treating 60, 30, and 14 days before a COA ages out as three separate checkpoints, each with a different action (confirm the next lot is coming at 60, request the document at 30, treat it as urgent at 14) rather than waiting for a single deadline and finding out too late.