Complying with the CPSIA/CPSC tracking label requirements
Kathleen of Fashion-Incubator.com has provided invaluable information for the garment industry on how to comply with the monstrous CPSIA law. No matter if you make 1 or 1000 garments or toys to sell, you must follow the law. Her articles on the CPSIA and specifically the tracking issue are a MUST read. Seriously, you should go read now and then come back here. Let's go!
The CPSC recently gave some guidance as to what the labels must say.
- Business Name/RN
- City, State and Country of Manufacture
- Date of Manufacture
- Batch #
- Cohort (if any)
As you can see I included what the FTC wants on the label as well. Namely fabric content, country the fabric came from and washing instructions. You may not need a batch number on the label but you must keep records of the materials used on a certain date range.
The CPSC FAQ page states this: "What kind of tracking system do you currently use? You do not necessarily have to create a new system of lot, batch or run numbers to identify when you made your products, however your products and their packaging should identify your company in sufficient detail to enable a consumer to reach you so that the required information may be ascertained."
"How is your product marked?
If someone had one of your products sold last year, would they know who to call if there was a problem? Absent any unusual circumstances, your business name should be on your product with sufficient detail to enable a consumer to reach you. Congress recognized that there could be instances where marking a product might not be practicable, such as where the product is very small. Consider the examples outlined in the Statement of Policy where it might not be practicable to mark a product."
You can see from my example, I left blank spaces to fill in the batch number as well as the DOM. Many people have found that a black cheap ball point pen is one of the best tools for writing on our satin labels. I included my business name as well as my website so the customers can contact me if they need to. Miss Label can print labels with blank lines or printed labels with a batch number and a date or date range, Jan-March 2009, etc. (no my labels are not 100% cotton, it's just an example)
"Is the information ascertainable if I mark my product and packaging with a code and website address where all the required information can be found?
Yes, provided the name of a manufacturer or private labeler is also identified so a consumer without access to the internet can know whom to contact directly to also obtain the required information."
I think this question from the site really sums up the importance of somehow marking your label with information as well as keeping very good records of materials used at home:
CPSC FAQ: What information can be ascertained about your product?
If someone handed you one of your products sold last year, what would you be able to tell them about the materials used? Keeping your receipts and purchase orders will help you to better know the source of your product and its components and when you began using them. Ask your fellow hand crafter's if they have any tips or ideas that can help."
Please note I am not a lawyer. This is just general information I have gleaned from the CPSC website. Please consult a lawyer for specific information regarding your business. Do not reprint article without permission.