We recently discussed a familiar request: the product structure is unchanged, so can the buyer add another colour without repeating the full test programme?
Not every new colour automatically requires every physical test to be repeated. But a colour change should never be treated as paperwork only.
The correct verification depends on the product standard, certificate status, materials, printing and the certification body’s rules. Buyers should confirm the update route before ordering production fabric.
Why Colour Can Affect Compliance
For an EN 13138-1 swimming aid, a new colour arrangement may affect visibility in water. Darker upper-body panels can create a different result even when the pattern and foam remain unchanged.
Colour may also come from a different dye, ink, coated fabric or printing process. That can affect colourfastness, chemical documentation and the durability of printed warnings.
So the useful question is not “Did the pattern change?” It is “Which compliance characteristics can this colour or material change affect?”
What the Reviewer Needs to Know
If the approved structure, dimensions and components remain identical, the certification body may focus on colour-related items rather than repeating unrelated work. However, that decision belongs to the laboratory or certification body.
The buyer and factory should provide a clear change description:
- Old and new colour layouts
- Exact panels that changed
- Fabric and ink supplier information
- Whether the base material is unchanged
- Warning-print artwork and method
- Current report and certificate references
This helps the reviewer determine what evidence or samples are needed.
The next step is to prepare representative samples, but only after the sample plan is confirmed.
During our laboratory discussion, one practical option for some colour updates was to provide a complete colour sample together with fabric carrying the actual printed warnings or repeated text. This can be more useful than producing many finished garments before the sample plan is confirmed.
It is not a universal rule. Sample quantities and test items vary by project. The important point is to ask first, then prepare the exact material the laboratory needs.
Do Not Certify Every Possible Colour Too Early
Some factories or brands try to approve a large colour range before real customer demand exists. That can tie up budget in combinations that are never ordered.
A more controlled strategy is to certify the main commercial colours first, then add colours in response to confirmed programmes. This also makes it easier to control the actual fabric, print method and supplier used for each update.
There is one timing issue to watch: an update may not restart the validity period of the original certificate. The certification body should confirm how the update affects dates and future renewals.
Once a new colour is accepted, the factory needs a controlled record linking the approved artwork, material, supplier, print method and certificate update. Production should not use an approximate shade or substitute material just because the marketing colour name is the same.
A staged colour strategy is usually more practical: approve the combinations the market needs, keep their material records clear and review each genuine change before production.