
In many countries under FCI rules puppies and dogs under 15 months are not eligible for CC's and also there has to be a year and a day between first and qualifying awards for a champion, so no dog can become a champion before it reaches 1 year 3 months + 1 day.
Fortunately we do not have this in UK, as it is pretty difficult to get them, with rationing and competing with the best on the day including champions, but a dog must be over 12 months old to become a champion.
One of mine won 2 CC's and several reserves as a puppy, and became a champion at 14 months. She had a CC the following year, and in between two litters has notched up quite a few reserves since.
My other two champions one won her first CC in Junior, the other at 20 months, the first has 10 CC's, and the other has 7 (with 4 won in veteran).
When a puppy wins the CC I do think it quite a sad reflection on the adults present, and generally think it better that a cracking puppy win the Reserve on it's promise, but if it really is the best on the day, then CC it should have.
From an exhibitors point of view winning a CC with a puppy can make it very difficult when almost inevitably the pup goes through the awkward immature adolescent stage (in my breed this can be from 12 months to three years, in males, and almost as long with some bitches, as they are so slow maturing), as they then look wrong and outclassed in Limit.