Checked against sources: 22 September 2026
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. Sources (4)CPSCCPSC: Product Registry FAQ V1.4 (PDF)CPSCCPSC: eFiling FAQeCFReCFR: 16 CFR Part 1107CPSCCPSC: Product Registry User Guide V3 (PDF)
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 and pricing.
Sources
Primary sources first; provider pages only for their own prices.
- CPSC: Product Registry FAQ V1.4 (PDF) — read 2026-09-22
- CPSC: eFiling FAQ — read 2026-09-22
- eCFR: 16 CFR Part 1107 — read 2026-09-22
- CPSC: Product Registry User Guide V3 (PDF) — read 2026-09-22
Founder of ComplyGoods. Publishes open data on product-compliance regimes (also eprfrancerep.com and eprgermanyrep.com). Every figure here links to the government file or provider page it was read from.
Razvan Toma on LinkedIn ↗