Do I need a separate CPC and lab test for each color, size or SKU?
One certificate per product, which is not always one per SKU. Colors or sizes that differ in a way that could affect compliance, such as a different paint, are separate products. Apparel in one material across styles, sizes and colors, made and tested together, is one product. A component tested once can support every product using it.
The rule, and what “one product” means
Each finished product certificate must describe only one product 16 CFR 1110.13(a). CPSC’s Product Registry FAQ explains: products are unique when a material change separates them — design, manufacturing process or source of components — so different colors of one model are separate products if such a change applies. Apparel items from the same material in several styles, sizes and colors are one product if they were manufactured and tested together Registry FAQ, Q12.
Typical cases
| Case | Certificates | Why |
|---|---|---|
| A T-shirt in 5 sizes and 4 dyed colors, one fabric, made and tested together | Usually one | CPSC’s apparel reading Registry FAQ v1.4; dyed textiles are excluded from lead testing 16 CFR 1500.91(d)(7) |
| A wooden toy in 3 paint colors | Usually one per color | A different paint is a different component that could affect compliance; each paint used must be shown compliant 16 CFR 1109.11 |
| The same design from a second factory | Separate | Certification test records are kept per manufacturing site 16 CFR 1107.26(a)(2) |
Share tests, not certificates
A component tested once — a paint, a fabric, a zipper — can support every product that uses it, if the tested part is identical in all material respects 16 CFR 1109.5(a) 16 CFR 1107.20(c). Paints and components can even be tested together as a composite, as long as the method cannot hide a failure 16 CFR 1109.21. Each product still gets its own certificate, listing the tests it relies on.
When a new color or supplier needs a new test
A new paint, a new component supplier, or a different part from the same supplier is a material change when it could affect compliance: test the changed part at a CPSC-accepted lab and issue a new certificate 16 CFR 1107.23(d).
Send us your catalog. Our free check applies CPSC’s one-product reading to it and tells you how many certificates you need and which tests can be shared. Each certificate is $79; the Catalog Plan covers up to 10 new or updated certificates a month for $149.
Last reviewed: September 30, 2026 · First published: September 30, 2026 · Not legal advice.
Sources read September 30, 2026
- 16 CFR 1110.13 — Certificate availability and eFiling
- CPSC, Product Registry FAQ v1.4 (updated Apr. 28, 2026)
- 16 CFR 1500.91(d)(7) — Lead content determination for textiles
- 16 CFR 1109.11 — Component part testing for paint (each paint used)
- 16 CFR 1107.26 — Recordkeeping for children’s products
- 16 CFR 1109.5 — Relying on another party’s tests or certificates (due care, documentation)
- 16 CFR 1107.20 — Certification testing of children’s products
- 16 CFR 1109.21 — Composite testing of paints and component parts
- 16 CFR 1107.23 — Material change