What do the Wii Fit Trainer, Luigi (SSB), Toon Link, Lucina, and Pac-Man amiibo figures for Super Smash Bros. all have in common? As of this writing, they all have exactly two months listed as their “date of manufacture” on their CPSIA Certificates of Compliance. Collectors everywhere are aware of this and have begun using the certificates as a figure rarity guide. When you think about it, though, was Luigi really as hard to find as the Wii Fit Trainer? Will Lucina be as plentiful on May 29th as Toon Link was at Toys“R”Us stores back in late January?

There are plenty of misconceptions about these CPSIA Certificates, which can be found when visiting the URLs printed on the backs of each amiibo’s packaging. While they can serve as a vague indicator of amiibo availability, not understanding how the certificates are issued and how they fit into the big picture can lead to the spreading of misinformation. Let’s fix that.

What are CPSIA Certificates of Compliance?

The Consumer Product Safety Improvement Act was passed by the U.S. Congress to establish safety standards for children’s products, most importantly regarding the quantities of potentially dangerous chemicals used in the materials found in those products. The manufacturer (or in this case, the importer – Nintendo of America) issues the certificate to prove their products comply with the established regulations.

The CPSIA Certificates for Nintendo’s lines of amiibo figures can be found at cpsia.nintendo.com, where they are updated as needed. They include potentially useful information for consumers, such as the “dates of manufacture” which have caught the attention of amiibo collectors.

What exactly is the “Date of Manufacture”?

According to the U.S. Consumer Product Safety Commission, which regulates manufacturing, importation, and sale of consumer products, the “date of manufacture” is defined as follows (emphasis added):

“Products may not always be made in a single day. Therefore, the date of production could be a range of dates if the product is made over a period of time. When the product is a group of disparate components or items assembled together or gathered into one package, the Commission interprets the date of manufacture to mean the date of assembly or placement into one package.”

This means that the “Jan 2015, Feb 2015” date listed for both the Lucina amiibo and Pac-Man amiibo indicate that these figures were assembled during those two months. Does this mean they’ll be of equal rarity? No. If you’ve ever been hardcore into custom painting amiibo or have seen work-in-progress photos from someone that is or was, you know amiibo are made up of many smaller components. Even though they were assembled in January and February, the individual parts could have been manufactured in December, or since October, or maybe even earlier than that. Lucina’s final design and assembly are far more complex than Pac-Man’s, so naturally you’d expect the assembly of one Lucina figure would require a bit more time than that of a Pac-Man figure. When you’re dealing with tens or hundreds of thousands of each figure, the number of Lucina figures produced in a two month span will likely be far less than the number of Pac-Man amiibo.

Listing production by months is extremely vague.

Complexity isn’t the only factor to consider. The CPSIA Certificates only indicate months in which the figures were manufactured (i.e., assembled), not specific dates. For example, both Lucina’s and Pac-Man’s amiibo’s certificates would read “Jan 2015, Feb 2015” even if Lucinas were, hypothetically, assembled during a lengthy January 5th through February 27th timespan and all the Pac-Man only assembled over a brief January 26th through February 6th span. They would also still read “Jan 2015, Feb 2015” if the Pac-Man figures were the ones assembled for several weeks from Jan. 5th through Feb. 27th, and the Lucina amiibo assembled in the mere two-week span of Jan. 26 through Feb. 6.

It doesn’t end there, either. The certificates carry no indication of volume. The manufacturer to whom Nintendo outsources amiibo production might have allocated multiple assembly lines to the Pac-Man amiibo, but only one line to the Lucina amiibo. Or vice versa. Or anywhere in between. Even if both figures took the same amount of time to assemble and were assembled on the exact same dates, if the Pac-Man figure was given twice as many assembly lines as compared to Lucina, we’d end up with twice as many Pac-Man amiibo.

Furthermore, since the Wii Fit Trainer amiibo‘s assembly months were at the very beginning of the amiibo production timeline (August and September), it’s quite possible that their assembly lines weren’t yet running at full speed or full capacity, potentially resulting in fewer figures, even if all other factors were equal. Also, keep in mind that these manufacturing contracts were likely in place and the assembly lines allocated long before Amiibomania set in. It’s possible Nintendo moved swiftly to arrange for larger production capabilities once the demand became apparent. Even if that were the case, it might not become immediately apparent due the growth of the craze outpacing their ability to secure facilities that would likely be tied up with the production of other products.

So are CPSIA Certificates useless for determining rarity?

I wouldn’t say they’re completely useless, but given additional factors such as the complexity of assembly, the actual dates of assembly within each month, the number of assembly lines dedicated to each figure, and even more factors beyond those, going by production months alone is inherently going to paint a very rough picture. Because of this, don’t use the CPSIA Certificates as the end-all, be-all guide to amiibo availability in North America, and don’t panic just because you see one month listed for that Charizard figure.

What do the CPSIA Certificates really mean about our precious amiibo figures? In actuality, they should mean fairly little to collectors. They’re just one piece of the larger puzzle.