Tracking Labels

Children’s Products Must Now Have Tracking Labels

Manufacturers sometimes have trouble finding products that were recalled; more importantly, parents can’t always easily identify recalled products. To address these problems, the Consumer Product Safety Improvement Act of 2008 (CPSIA) requires manufacturers to affix permanent tracking labels to most children’s products. Manufacturers vigorously opposed this improvement, but the Consumer Product Safety Commission stuck to August 14, 2009, as the effective date for the new tracking label requirements.

The tracking label requirement applies to products manufactured after the August 14, 2009 date. To be deemed adequate and in compliance, any such tracking labels must enable the manufacturer and the consumer to ascertain the following product information:

  • Name of the manufacturer or private labeler;
  • Date (or date range) of production;
  • Location of production (country, state and city is sufficient for the label, but the manufacturer must also know the building);
  • Cohort information (e.g., batch, run number or other identifying characteristic);
  • Other information that would allow the manufacturer to determine the source of the product.

Beyond these requirements, the Act doesn’t require a uniform system for labeling. But each manufacturer is charged with making “a reasonable judgment about what information can be marked on their product and packaging, given the character and type of their product and packaging, and what required information can be ascertainable, given the character and type of their business.” And there are some exceptions to the labeling requirement, of course, such as for certain disposable packages (if there’s a label visible through the packaging on the product itself), vending machine products, and where aesthetically or structurally impracticable.

But despite the various exceptions, the Consumer Product Safety Improvement Act is an improvement that has now gone into effect, and that will permit parents to safeguard their children’s well-being with greater certainty.

 

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