Tracking Labels For Childrens Products - US Consumer Product Safety Commission


by Mark Trumper - Date: 2010-01-28 - Word Count: 494 Share This!

A recent law known as the Consumer Product Safety Improvement Act (CPSIA)came into force last year and one section in particular deals with the requirement for tracking labels to be affixed to every product intended for use by children.

Section 103(a) of the new legislation makes it mandatory for manufacturers to affix a tracking label on every product intended for use by children aged twelve or younger. The law applies even if the product is not exclusively intended for use by children but simply "primarily intended" for use by children. The tracking label must include information such as the source of the product, the date the product was manufactured and detailed information to enable tracking the product to a specific batch or product run.

This is a very wide ranging definition - "all" means all in this instance - every product for children twelve and under must now include a tracking label and comply with the new law, and this includes the following:

•Toys
•Candy
•Clothes
•Shoes
•Food
•School equipment
•Playground apparatus
•Furnishings (for use by children)
•Furniture (for use by children)

Note this list is not exhaustive - every product primarily intended for use by children twelve and under is caught. For instance, someone who makes furniture in their spare time must include labelling information if the product is primarily intended for children under twelve. It also should be noted that the Consumer Product Safety Commission tasked with overseeing the legislation, is also given the power to extend the use of tracking labels to other consumer products for use by adults as well.
The new law came into effect on August, 14, 2009, one year after Congress enacted the bill to become legislation.

Many manufacturers have been operating under the mistaken belief that the new law only applies to imported products and that domestic manufacturers are not caught by the legislation. This is not correct and all domestic manufacturers must comply.

Hang tags and adhesive labels are prohibited from being used as tracking labels because they are not considered to be sufficiently permanent to meet the requirements of the legislation.

One grey area which exists is in the minimum amount of information which must be present on a tracking label - the law states that, "to the extent practicable" the label must show the manufacturer (or private labeler), the place of manufacture and the date of production along with "cohort" information. What constitutes "to the extent practicable" is not yet clear, but the Commission intends to issue guidance on this including the size and location of the labelling on products.

The position of the Commission is that ultimately, manufacturers are responsible for exercising a reasonable level of judgment about what information is marked on their products and product packaging. Where a manufacturer departs from the requirements of s103(a), the manufacturer must only do so for "considered and definable reasons".

One thing is clear about the new law; it has generated a huge number of questions amongst manufacturers, large and small, as to what they have to do to satisfy the requirements of the new law.


By Mark Trumper, President of MaverickLabel.com, the Internet's leading provider of custom labels, stickers and decals. From labels, to window decals to product labels, MaverickLabel.com can provide all of your label needs. Call 1-800-537-8816.n
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