Selling on Amazon could require a GTIN exemption form. 

The exemption via letter template will work if the SPOD merchant is planning to sell their products under the brand name "SPOD".

If the SPOD merchant uses/wants to sell his products under a different brand name, the exemption may not work.

To do this for a different brand name, it would be best to register the brand on Amazon Brand Registry or registering a trademark off Amazon and request a UPC/GTIN exemption which is usually granted without problems for private label brands.

Please find a GTIN exemption letter from SPOD here: GTIN_Exemption_Letter_SPOD.pdf