# Does every SKU need its own CPSC certificate? > CPSC's rule: one product per certificate, and a material change (design, process, component source) makes a new product. How colours, sizes, apparel and factory changes are treated. Checked against sources: 22 September 2026 · https://complygoods.com/guides/does-every-sku-need-a-cpsc-certificate/ ## Quick answer Not every SKU, but every unique product. CPSC does not allow several similar products on one certificate, and treats two products as unique when there has been a material change, such as to the design, the manufacturing process or the source of components. Colour variants need separate certificates only if such a change applies. Apparel of the same material in several styles, sizes and colours is one product if manufactured and tested together. ## The rule, in CPSC's words Product Registry FAQ, question 12: users "must create a separate certificate for each unique product. CPSC considers two products unique if there has been a material change, such as a change to the design, manufacturing process, or source of components. Different colors of the same model would be considered unique products and, therefore, would require a separate certificate if a material change, as described above, applies."

## Common cases | Situation | Separate certificate? | | Same toy, new colour made with a different paint supplier | Yes: component source changed | | Same toy, new colour, same materials and suppliers | Not required by the colour alone | | T-shirt in 5 sizes and 4 colours, same fabric, made and tested together | One product | | Same product, moved to a new factory | Treat as a material change: new testing and a new certificate version | | Annual retest of an unchanged product | Same product, new certificate version (new Version ID) | ## Why the count matters Certificates drive cost: CPSC's rule assumed each certificate generates about 23.7 filings a year. A catalogue's real certificate count is usually different from its SKU count, which is why our plans count active certificates rather than listings. See [market size](https://complygoods.com/data/efiling-market-size/) and [pricing](https://complygoods.com/pricing/).

## Sources - CPSC: Product Registry FAQ V1.4 (PDF): - CPSC: eFiling FAQ: - eCFR: 16 CFR Part 1107: - CPSC: Product Registry User Guide V3 (PDF): --- ComplyGoods · https://complygoods.com/guides/does-every-sku-need-a-cpsc-certificate/ · Independent. Not affiliated with or endorsed by the U.S. Consumer Product Safety Commission (CPSC) or U.S. Customs and Border Protection (CBP).