Magnuson-Moss Warranty Act for Amazon Sellers: Full vs Limited Warranty, $10 and $15 Rules
Federal law does not make an Amazon seller offer a warranty, but once you put one in writing on a consumer product, the Magnuson-Moss Warranty Act and the FTC’s rules decide how it must be worded and shown. Per the FTC’s business guide (checked 2026-10-08), a written warranty on a product costing more than $10 must be titled “full” or “limited,” and the disclosure and pre-sale availability rules apply above $15. Clauses that void coverage when a buyer uses third-party parts were the subject of FTC warning letters in 2018 and 2024.
This guide covers only federal law on the warranty text a seller writes. Amazon’s returns and A-to-z claims are separate; see A-to-z Guarantee claims and the Amazon return window. Nothing here is legal advice; it restates the official texts so you can check your own wording against them.
Sources: the FTC’s Businessperson’s Guide to Federal Warranty Law, 16 CFR Parts 701 and 702 on eCFR, and FTC press releases from 2018 and 2024, all read 2026-10-08. Quotes are from the FTC guide unless marked otherwise.
Does the Magnuson-Moss Warranty Act Apply to Your Listing?
Three tests decide whether the Act reaches your product page.
It has to be a consumer product. The FTC guide says “only warranties on tangible property normally used for personal, family, or household purposes are covered.” Products bought solely for commercial or industrial use are excluded from the pre-sale rule by 16 CFR 702.1(b).
The warranty has to be written. The guide states that “Only written warranties are covered.” Under 16 CFR 702.1(c), a written warranty is a written promise that material or workmanship is defect free or will perform at a specified level for a specified period, or a written undertaking to refund, repair, replace, or take other remedial action if the product fails to meet the stated specifications. A listing line such as “2-year warranty: we replace any unit that stops working” fits the second branch.
It is a warranty, not a service contract. The guide says service contracts are “separate from the contract or sale of the product,” because they are made after the sale or “cost the customer a fee beyond the purchase price of the product.” A paid add-on protection plan is a service contract, and the full/limited titling below does not apply to it.
Writing a warranty is a choice. The guide says plainly that “the Act does not require any business to provide a written warranty.”
The $10 and $15 Thresholds Are Two Different Rules
The two dollar figures trigger different obligations (FTC guide, checked 2026-10-08):
| Product cost | What applies | Where the requirement comes from |
|---|---|---|
| More than $10 | Title the warranty “full” or “limited” | The Act itself |
| More than $15 | Required disclosures in the warranty text, plus availability before sale | FTC Rules (16 CFR 701 and 702) |
In the guide’s words: “The titling requirement, established by the Act, applies to all written warranties on consumer products costing more than $10.” It then says “the disclosure and pre-sale availability requirements, established by FTC Rules, apply to all written warranties on consumer products costing more than $15.”
The rule text is specific about measurement. Both 16 CFR 701.3 and 702.3 apply to a consumer product “actually costing the consumer more than $15.00.” If coupons or deals move your price around that line, read that wording against your own pricing; the official texts do not discuss marketplace promotions.
Full vs Limited Warranty: The Five-Condition Test
The FTC guide gives a five-part test. If all five statements are true, the warranty is full:
| # | Condition for a full warranty (FTC guide wording) | Example wording that fails it |
|---|---|---|
| 1 | “You do not limit the duration of implied warranties.” | “Implied warranties are limited to the warranty period” |
| 2 | “You provide warranty service to anyone who owns the product during the warranty period.” | “Valid for the original purchaser only” |
| 3 | “You provide warranty service free of charge.” | “Buyer pays return shipping for warranty claims” |
| 4 | “You provide, at the consumer’s choice, either a replacement or a full refund if, after a reasonable number of tries, you are unable to repair the product.” | “Replacement at our discretion; no refunds” |
| 5 | “You do not require consumers to perform any duty as a precondition for receiving service, except notifying you that service is needed, unless you can demonstrate that the duty is reasonable.” | “Valid only if you register within 14 days” |
The guide’s rule for the opposite case is one line: “If any of these statements is not true, then your warranty is ’limited.’” The third column is our illustration, not FTC text. A limited warranty is legal; the mistake is calling a warranty “full” when one of the five statements is false.
Two more points matter for listing copy:
- You can mix the two. The guide says “You are not required to make your entire warranty ‘full’ or ’limited’,” so a full warranty on the motor and a limited one on accessories is allowed if each is labeled.
- The title does real work. The guide says it “is intended to provide consumers, at a glance, with a key to some of the important terms and conditions of a warranty,” so put it where buyers read it first.
What a Warranty Over $15 Must Disclose
For products costing the consumer more than $15, 16 CFR 701.3(a) requires the warrantor to “clearly and conspicuously disclose in a single document in simple and readily understood language” nine items (checked 2026-10-08 on eCFR):
| # | Required item, summarized from 16 CFR 701.3(a) |
|---|---|
| 1 | Who the warranty covers, if it is limited to the original purchaser or otherwise not every owner |
| 2 | What products, parts, or components are covered, and exclusions where needed |
| 3 | What the warrantor will do if there is a defect, including what it will and will not pay for |
| 4 | When coverage starts (if not the purchase date) and how long it lasts |
| 5 | Step-by-step claim procedure, with the warrantor’s name and a mailing address, responsible department, or toll-free number |
| 6 | Any informal dispute settlement mechanism chosen under Part 703 |
| 7 | Any limit on the duration of implied warranties, with a prescribed state-law statement |
| 8 | Any exclusion or limit on incidental or consequential damages, with a prescribed statement |
| 9 | The statement “This warranty gives you specific legal rights, and you may also have other rights which vary from State to State.” |
The fixed sentence for item 7 is “Some States do not allow limitations on how long an implied warranty lasts, so the above limitation may not apply to you.” Item 8 has a parallel sentence on incidental or consequential damages, and the rule allows the two to be combined.
Item 7 ties back to implied warranties. The guide says “Federal law prohibits you from disclaiming implied warranties on any consumer product if you offer a written warranty for that product” and allows one carve-out: “If you offer a ’limited’ written warranty, the law allows you to include a provision that restricts the duration of implied warranties to the duration of your limited warranty.”
Making Warranty Terms Available Before Sale When You Sell Online
The Pre-Sale Availability Rule (16 CFR 702.3) splits duties between the warrantor, who gives the warranty, and the seller, who offers the product. Many private-label Amazon sellers are both.
As the warrantor. The guide summarizes the choice: “you must either post the warranty terms for the specific product on an internet website in a clear and conspicuous manner and provide a non-internet based method for consumers and sellers to obtain the warranty terms, or provide retailers of your product with the warranty materials they will need to meet their pre-sale obligations.”
If you pick the website route, 702.3(b)(2) adds four duties:
- Print the website address, plus a phone number, postal address, or other non-Internet way to request a copy, “in the product manual or on the product or product packaging.”
- Send a hard copy “promptly and free of charge” when a consumer or seller asks.
- Keep the terms posted clearly and conspicuously and accessible on the site.
- Make it easy to identify which terms apply to which product.
As the seller. Under 702.3(a), the seller must make the warranty text “readily available for examination by the prospective buyer,” by displaying it close to the product or furnishing it on request before the sale. The guide adds: “If the warrantor has supplied the warranty by posting it on the internet, the seller may provide it to prospective buyers in an electronic format.”
Part 702 also has a catalog and mail order paragraph, 702.3(c). It covers offers with “instructions for ordering the product which do not require a personal visit to the seller’s establishment,” and requires the seller to disclose, near the product description, either the full warranty text or the warrantor’s website address plus a note that a free copy is available on request and where to ask.
Neither the FTC guide nor Part 702 mentions Amazon (full-text check, 2026-10-08), so neither says which paragraph governs a marketplace listing. A conservative reading satisfies both: put the warranty text, or its web address and a free-copy contact, where buyers see it before checkout. For Amazon’s own compliance requests, see Manage Your Compliance.
Why “Warranty Void If” Clauses Are Risky
The FTC guide calls this a tie-in. Its prohibited example: “To keep your new Plenum Brand Vacuum Cleaner warranty in effect, you must use genuine Plenum Brand Filter Bags.” It also lists a seal clause, “This limited warranty shall not apply if the warranty seal has been broken, removed, erased, defaced, altered, or is otherwise illegible,” as prohibited where the device cannot be repaired without breaking the seal.
There are two exceptions. A warrantor can require specific items or services “if they’re provided free of charge under the warranty or the warrantor receive[s] a waiver from the FTC.” (The guide’s text reads “receiver”; the bracket fixes the typo.)
The guide shows wording that keeps protection without the tie-in: “Damage caused to the AudioMundo Stereo System by you or any non-authorized third party, however, may void this warranty.” The difference is causation. You can exclude damage a third party actually caused; you cannot make coverage depend on avoiding third-party parts or service.
The FTC has acted on this repeatedly:
| Date | FTC action | What was flagged |
|---|---|---|
| April 10, 2018 | Warning letters to “six major companies that market and sell automobiles, cellular devices, and video gaming systems” | Coverage conditioned on the company’s own parts, and seal clauses; staff said it would review the companies’ websites after 30 days |
| July 3, 2024 | Warning letters to eight companies | Five over requiring “specified parts or service providers” (air purifier sellers and a treadmill company); three over “warranty void if removed” stickers placed where they hinder routine maintenance and repairs |
The 2024 release says staff urged each company to make sure its materials “do not state or imply that warranty coverage is conditioned on the use of specific parts or services.” Air purifiers and treadmills are everyday Amazon categories, so this reaches marketplace sellers, not only automakers.
The guide lists no penalty amount. It notes that “Section 110(d) of the Act makes breach of warranty a violation of federal law, and enables consumers to recover attorneys’ fees.” For broader risk cover, see product liability insurance for Amazon sellers.
Warranty Wording Checklist for Amazon Sellers
Check your warranty text before it goes on a listing, insert, or package:
- Consumer product, written promise: the Act applies.
- Over $10: the title says “Full” or “Limited.”
- “Full” only if all five FTC conditions are true.
- Over $15: all nine 701.3 items in a single document, with the state-law sentences if you limit implied warranties or damages.
- No disclaimer of implied warranties alongside a written warranty; a “limited” warranty may only restrict their duration.
- No clause tying coverage to your own parts or repair shops unless they are free or FTC-waived.
- No seal clause on products that cannot be repaired without breaking the seal; use causation-based wording.
- Terms visible before purchase, and a non-Internet way to get a free copy printed on the product, packaging, or manual.
- Support staff know the claim procedure; see FBA customer service.
Shipping promises fall under a different FTC rule; see the FTC Mail Order Rule for FBM sellers. Origin claims are covered in Made in USA claims.
Frequently Asked Questions
Do Amazon sellers have to offer a warranty?
No. The FTC guide says “the Act does not require any business to provide a written warranty.” The requirements start once you give one in writing on a consumer product.
What is the difference between a full and a limited warranty?
A warranty is “full” only if all five FTC conditions hold: no limit on implied warranty duration, coverage for any owner during the term, free service, refund or replacement at the consumer’s choice after failed repairs, and no unreasonable duties beyond notifying you. If any one fails, it is “limited.”
Can I say “warranty void if you use third-party parts”?
Not as a general rule. The FTC treats conditioning coverage on specific parts or services as a prohibited tie-in unless they are free under the warranty or the FTC grants a waiver. Excluding damage actually caused by a non-authorized third party is the wording the guide shows instead.
Bottom Line
Offering a warranty is optional; wording it badly is the risk. Label it full or limited above $10, include the nine disclosures and show it before sale above $15, and swap any “void if” clause for damage-based wording. Keep it consistent with your listing copy.