Friday, January 27, 2012

CPSC and the CPSIA: Tracking Label Information for Children's Toys

We are continuing our series on the regulations related to the release on stay of enforcement of the CPSIA law which is requiring anyone from garage hobbyist to big box importer to tracking the materials, components, pieces and parts of all of thier toys and certify that they are lead free. This post covers the contents and format needed for the tracking labels- now required on all toys. I did a post on this last week and promised to come back with definite information.

The CPSIA requires all children's products manufactured on or after August 14, 2009 to bear a tracking label. This law includes small batch manufacturers as of 12/31/2011.

Here is a recap of what is required bu the CPSIA to appear on each label:
  • Manufacturer or Private Labeler Name
  • Production Location
  • Production Date
  • Cohort Information
    • Batch Number
    • Run Number
    • Other Identifying Characteristics

What is meant by Production Location:

  • Specific production location
  • Country of origin is not sufficient
  • This can be included in a code that would allow the manufacturer to distinguish where the product was manufactured without revealing the source to competitors
  • For small batch guys like me- I get to proudly say- Made in Texas. 

What is meant by Production Date:

  • Date product was manufactured
  • Can be coded
  • Example yyyymmdd
  • If you are wondering what happens when you have multiple parts- all made at different times-- just use the date you did the final touches. It will suffice.

What in the heck is Cohort Information?

  • Should include batch or run number or other identifying characteristics
  • Model number or item number, if applicable
  • Many companies utilize lot numbers - these should be included
  • Can be coded in the label as long as the manufacturer can use the information to track back to the factory and materials used for manufacture
  • For me- since there is not really "a lot" of anything I do in a workshop- I'll include the month and year and an abbreviation of the source of materials. If I bought it at Home Depot- I'll use HD. Colorado Heirloom wood strips will get CH. I think this answers the spirit of the law. There's not another lot number I can think of that would be of any use to anyone should they need to track down the origin of the wood. 

And Where Can I Stick This....Label? (I know- it's ripe)

  • Label must be permanent
  • Must be present on the product and packaging to the extent practicable
  • "Permanent" meaning it cannot be removed through use and abuse tests when conducted in accordance with ASTM F963
  • Good grief- thankfully I have an engraver and it will be permanent on most everything. For puzzles and concentration games there is not a requirement that the pieces get marked- but i can mark the box. My idea for this is to either include a piece that has this info or ModPodge a cardstock label to the inside of the box. It's pretty permanent and a little water resistant to boot that way. I could also just write on the box with a Sharpie marker... talk about homemade looking!

More ASTM Label Requirements (Good Grief)

  • These are the standards that result if silly things like  "don't put this plastic film in a baby's mouth" kind of statements and disclaimers on products. Look at it as CYA-
  •  ASTM F963 labeling requirements for products which fall under the scope of the standard (this includes most stuff that kids play with using their hands that won't outright kill them like an room-size inflatable or scooters or things that all kids stick in their mouths like art supplies- those are apparently covered under some other obtuse standard.)
    • Age grading
    • Safety labeling
    • Instructional literature requirements
    • Producer's markings
  • Toy or package must be marked with the name and address of the producer or distributor
Here is my label:
Sima Design (with my pretty logo picture)
Made with love in Grand Prairie, Texas
Created for you in Jan 2012  from CH-Maple
Made for kids 3+ (or whatever goes here- teethers would be all ages I guess?)
Warning: Lots of fun (or don't eat paste or watch for small objects) etc.- whatever is appropriate for that toy

I have to mark teethers this weekend. I've held on to them for a week now wanting to make sure I get this right-- I think we can safely move on ;)

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