Tracking labels for children’s products

CPSIA Section 103 requires new tracking labels for children’s products (intended for use by children 12 and younger).

While this requirement is new for many small manufacturers, it is not too difficult to implement, and is certainly a best practice.

From the CPSC website:

Section 103(a) of the new law requires manufacturers to have a tracking label or other distinguishing permanent mark on any consumer product primarily intended for children twelve and younger. The tracking label must contain certain basic information, including the source of the product, the date of manufacture and more detailed information on the manufacturing process such as a batch or run number. The scope of this provision is quite broad in that it applies to all children’s products, including, but not limited to, items such as clothing or shoes not just toys and other regulated products. Congress modified the requirement for tracking labels with the phrase “to the extent practicable” recognizing that it may not be practical for permanent distinguishing marks to be printed on small toys and other small products that are manufactured and shipped without individual packaging.

Most sewn products already have labels sewn into them that includes the name of the manufacturer (the brand), the country in which the product was made, and care and contents. If you make clothing and aren’t doing this, you are not in compliance with FTC regulations. Lucky for you, the FTC has written a handy manual to help you comply.

Expanding the information on your labels shouldn’t be too hard, and can be accomplished by sewing in one more label that has a lot tracking number. We combine two relevant bits of information into our lot numbers:

1. Date of manufacture, e.g. 20081218 would mean the batch was completed on 18 December 2008.
2. Place of manufacture is indicated not only by “Made in USA”, but by a code added to the front of the lot number, e.g. McK 20081218 would mean it was made in McKinney on 18 December 2008.

So combined, your brand name, country of origin, and spiffy new lot number will give you, your customers, and the CPSC all of the information needed to track a product back to the relevant tests performed for compliance.

This information also needs to appear on the outside of your packaging. Why? Other than being part of these new regs, it’s also best practice. Try identifying which products are subject to a massive recall if the lot number is only sewn under the care label of a product folded into a box. Been there, done that, cried myself to sleep. Put the lot number on the outside of the packaging. If you sell into any of the bigger stores, most started requiring it some time during 2007/08, if they didn’t already.

[This post has a permanent home here.]