Brands collect a lot of paper for compliance. Three documents come up again and again: supplier declarations, test reports and certificates of compliance. People mix them up, and that leads to gaps. This post explains certificate of compliance vs test report in plain words, plus where supplier declarations fit.
Key takeaways
- Supplier declaration: what the supplier says is in a material.
- Test report: what a lab measured in one sample.
- Certificate of compliance: your statement that the finished product meets specific rules, based on the evidence.
- You usually need all three, linked together.
The three documents
| Supplier declaration | Test report | Certificate of compliance | |
|---|---|---|---|
| Who writes it | Supplier | Lab | You (the brand/manufacturer) |
| What it covers | One material or component | One sample, one test | A finished product and specific rules |
| What it proves | What the supplier knows and states | A measured result at a point in time | That the product meets named rules, based on evidence |
| Strength | Covers chemistry you can't see | Objective data | Ties everything together |
| Weakness | Only as good as the supplier's knowledge | Only covers what was tested | Only as good as the evidence behind it |
Supplier declaration
A signed statement from a supplier about a material: for example, "No PFAS has been intentionally added to this fabric." It's the main way to learn about chemistry used upstream, like finishes, processing aids and coatings. See our supplier declaration template.
Use it for: every material in every product.
Test report
A lab's result for a sample: for example, "Total organic fluorine: <10 ppm." It's objective, but limited: one sample, one method, one moment.
Use it for: high-risk materials, spot checks, filling gaps when suppliers can't answer, and where a law sets a numeric limit (like California's 50 ppm textile limit from 2027). See TOF testing explained.
Check: that the sample matches the material you buy, the method fits the rule, and the reporting limit is low enough.
Certificate of compliance
Your formal statement that a finished product meets specific rules. It names the product, lists the rules, cites the evidence (declarations and tests), and is signed and dated by someone accountable.
In the US, some certificates are required by federal law: for example, a Children's Product Certificate (CPC) for children's products, based on testing at a CPSC-accepted lab, and a General Certificate of Conformity (GCC) for certain other consumer products. State PFAS laws generally don't prescribe a certificate format, but California's AB 347 framework and retailer programs increasingly ask for one. See AB 347.
In the EU, the packaging equivalent is the EU declaration of conformity under PPWR. See PPWR declaration of conformity.
How they work together
Think of it as a pyramid:
- Bottom: supplier declarations for every material.
- Middle: test reports for the riskiest materials.
- Top: a certificate of compliance for the finished product, citing both.
If the bottom is missing, the top is a guess. If the middle is missing for high-risk materials, the top is weak.
Common mistakes
- Treating a supplier's certificate as yours. A mill's certificate covers the fabric, not your finished jacket with its zipper and trims.
- One test for a whole product line. Different colors and lots can differ.
- Certificates with no evidence behind them. If asked, you need to show the declarations and tests.
- Old documents. Evidence should match current materials and suppliers.
Building a strong set for PFAS
Per product:
- Bill of materials listing every component
- Declaration per component
- Test reports for high-risk components
- A one-page certificate or conclusion: "Product X meets AB 1817 (50 ppm), Minnesota Amara's Law bans, and contains no intentionally added PFAS, based on the attached evidence." Signed and dated.
See the audit-ready compliance evidence file.
Example: the document set for a kids' rain jacket
| Layer | Document | Who | Notes |
|---|---|---|---|
| Declarations | Shell fabric, lining, zipper, snaps, reflective trim, labels | Each supplier | Signed, dated, material-specific |
| Tests | TOF on shell and zipper tape | Accredited lab | Below 50 ppm |
| Federal certificate | Children's Product Certificate | Brand | Based on CPSC-accepted lab testing for applicable safety rules |
| PFAS conclusion | One-page statement covering AB 1817, AB 652, Minnesota and Maine juvenile/textile bans | Brand officer | Cites declarations and tests |
Each layer answers a different question. Together, they hold up.
How long is each document good for?
There's no single rule, but a practical approach:
- Supplier declarations: refresh yearly for high-risk materials, or on any change.
- Test reports: valid for the material and lot tested; retest high-risk materials yearly or on change.
- Certificates and conclusions: update whenever underlying evidence or rules change.
Note the date on everything. Undated documents are hard to rely on.
Questions teams ask
"Can a supplier's test report go into our certificate?" Yes, if it covers the exact material and method you need, from an accredited lab, and is recent.
"Do we need a lawyer to sign certificates?" No. A responsible officer at your company signs. Counsel can review the template.
"What if a retailer has its own certificate form?" Use it, but build it from the same evidence file so answers stay consistent.
Document checklist per product
- Bill of materials with every component
- Declaration per component
- Tests for high-risk components
- Federal certificates where required (CPC or GCC)
- Signed PFAS conclusion
- Dates and refresh schedule noted
What to do this week
- Pick one product and gather its three document types in one folder.
- Note any gaps, such as components with no declaration.
Key terms
- CPC (Children's Product Certificate): A federal certificate for children's products based on third-party testing.
- GCC (General Certificate of Conformity): A federal certificate for certain other consumer products.
- Accredited lab: ISO/IEC 17025 certified for the method used.
- Declaration of conformity (EU): The PPWR packaging equivalent of a certificate.
Mistakes to avoid
- Filing a supplier's certificate as your own product certificate.
- Using one test to cover materials it didn't test.
Still have questions?
"Should certificates be shared publicly?" Usually not. Share with regulators, retailers and partners on request.
"Do we need a certificate per SKU?" Group SKUs that share identical materials, but name every SKU covered.
The bottom line
Declarations tell you what suppliers know, test reports show what a lab measured, and certificates tie it all to your product. You need all three, linked and dated, for evidence that holds up.
How Secuabase helps
We collect declarations, match tests to components, and draft a certificate-style conclusion per product for your officer to review and sign. Every statement points to its source document. We never sign on your behalf.
For our first partners we run it free on one product line. Book a quick chat.
FAQ
What is a certificate of compliance?
Your certification that a product meets named rules, citing the evidence. Some, like the CPC, are required by federal law.
Is a test report enough?
No. It covers one sample; you also need declarations and a certificate linking evidence to the product.
Which document do regulators ask for?
It depends on the law; many PFAS laws ask for information or tests on request.
General information, not legal advice. Facts checked October 2026.
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