CPSC Business Education I Tracking Label Requirement

Summary

This video provides an overview of the CPSC's tracking label requirements for children's products, emphasizing the importance of tracking labels in identifying product origins for recalls. It outlines the necessary information to include, such as manufacturer details, production location, and dates, while highlighting the need for permanence and visibility. The video also addresses practical challenges manufacturers may face when affixing labels and offers examples of compliant and non-compliant tracking labels. Resources for further guidance are provided, ensuring that manufacturers understand their obligations under the Consumer Product Safety Act.

Takeaways

• 😀 Tracking labels are required on children's products under the Consumer Product Safety Act (CPSA) to help identify products for recalls.
• 📦 Tracking labels must be affixed to both the product and its outer packaging whenever practicable.
• 👶 Children's products are defined as consumer products designed for children aged 12 years or younger.
• 📍 Tracking labels should include information such as the manufacturer, location of production, date of production, and cohort information.
• 🔍 The commission has not specified size, location, or format for tracking labels, as requirements may vary by product type.
• 🛠️ Companies must maintain a record of justifications if a tracking label cannot be affixed to the product itself.
• 🧩 For complex products with multiple components, tracking information can be provided through batch codes and website links.
• 🧸 Permanent labels are crucial; options like molded labels or waterproof stickers are recommended to ensure longevity.
• ❓ If products are already labeled for other requirements, they can satisfy tracking label requirements if the necessary information is included.
• 📞 Small batch manufacturers must also comply with tracking label requirements, regardless of business size.

Q & A

What is the purpose of tracking labels in children's products?

Tracking labels help identify when and where a product was made, facilitating targeted recalls if necessary.

Who is required to include tracking labels on children's products?

Manufacturers, importers, and private labelers must include tracking labels on children's products intended for those aged 12 and younger.

What information must be included on a tracking label?

A tracking label must include the manufacturer's details, location of production, date of production, and any additional identifiers such as batch or run numbers.

What does 'to the extent practicable' mean in the context of tracking labels?

'To the extent practicable' means that manufacturers must make reasonable judgments about how to affix tracking labels based on product characteristics and type.

Can tracking label information be provided in code form?

Yes, tracking label information such as location and date of production can be represented in code form as part of a batch code.

What happens if it's not practicable to affix a tracking label directly to a product?

If it's not practicable to affix a tracking label to the product, the packaging must still carry the tracking label information.

Are there size and location specifications for tracking labels?

No, the CPSC has not provided specific size, location, or format specifications for tracking labels, as these may vary by product type.

What should a manufacturer do if they choose not to mark a product?

Manufacturers should maintain a list of justifications for not marking the product if it is not practicable.

What examples were given for compliant tracking labels?

Examples include a silicone bubble fidget toy with tracking labels on both the product and packaging, and a baby rattle using a date wheel on its product label.

How does the requirement affect small batch manufacturers?

Small batch manufacturers must comply with tracking label requirements regardless of business size, ensuring their products and packaging are marked appropriately.