For hobby sellers, the most difficult part is meeting the "25 sales during Sep-Oct" requirement. To meet this, I typically unload minifigs and polybags during the requirement window. The requirement is for 'sales', but they don't need to be high value items, or even toys. Polybags are easy to store, pack, and ship, and one only needs 3-4 sales a week to meet the requirement. Even if I sell them for a small loss, I easily make it up through the price difference and volume gain during Nov and Dec compared to selling on other channels.
If you don't have minifigs or polybags on hand for this year, plan ahead for next year. Target seasonal clearance and CMF boxes are a good steady source. Friends Animal polybags (which EE had on sale at 30% off earlier this week) are good too. [i miss the days when magnet figs were not glued to the magnets. When they went on sale, they were a home run for this purpose.]