As Monte Cook said on his site about 3e item creation, the caster level is never a requirement, unless it specifically notes it after the word "pre-requisites". The listed CL is only ever the average caster-level of a generic item of that type.
Except that in one place the Pathfinder rules specifically states that CL must be met by a magic item's creator.
We need to know if that's an intended change or an oversight. We need an official ruling from the designers of the Pathfinder Core Rules, rather than a past edition of D&D.
Seriously.. this needs to be clarified by Bulmahn. I see both interpretations, but the language is not clear.
No one should be opposed to the asking for a definitive response, especially if they believe they are correct.
I'm certainly not opposed to a definitive answer - trust me I want it as much as or more than anyone.
That said, pretty much identical wording was released during the beta, and had its meaning explained. I feel that sets a baseline expectation while waiting for clarification.
As Monte Cook said on his site about 3e item creation, the caster level is never a requirement, unless it specifically notes it after the word "pre-requisites". The listed CL is only ever the average caster-level of a generic item of that type.
So if my 3rd level caster somehow gets his hands on 100k, I can make a CL 20 item on a good dice roll? Seems a little wonky to me.
I really don't think the caster level listed for items is a prerequisite, I think its a hard rule, like the feat. Some of the CL's might seem a little off, but if you start looking at it as a guideline to complexity of the item (a Belt of Physical perfection is harder to make than a Belt of Physical Might, which is harder than a Belt of Strength) it tends to make a bit more sense.
It would be nice to get an official word on this.
What you're not allowed to do is create a CL 20 item when you're only a 3rd level caster.
Actually, the whole point is that you are allowed to. It's just likely to be cursed, because the DC is either 30 or 35 depending on which RAW you read.
An Elf with Skill Focus and Magical Aptitude can make the former roll on a 17, though. A successful assist check from a laboratory partner brings even the latter into reach... or if the 5+CL rule is really the right one, allows a spell not known by the caster to be used.
Mind you, the item can only be a scroll, wand or potion which makes the usefulness of setting it at CL20 rather limited.
Edit: Actually, if the CL isn't a prerequisite at all, that puts the DC as low as 5+20 = 25.
Caster-levels were always weird and Monte Cook specifically said that the "rule" about using CL as a prerequisite was simply a mis-stating or misreading of the rules. So, yes, in this case, we do need a clarification as to whether the required CL in PF is necessary or simply an error copied over.