Thursday, January 19, 2012

CPSC Continued: All Toys must have a Tracking Label

A Tracking Label
(See previous posts on CPSC compliance for itty-bitty toy makers here and here.)

So as it turns out- all of my products sent out as a child's toy must have a tracking label on both the packaging and on the toy. The requirement is that children's products designed for use by those under 12 years old must have a permanent mark known as a tracking label. This label must identify the product and packaging with basic infomration about its manufacture including:
1. The name of the manufacturer (Me)
2. The location and date of manufacture (Easy enough)
3. Something to identify the process used to make it (this is consistent so I'll make up a fancy name for it)-- others may have a batch or run number- I'm not making zillions of these so batches are individual- I'll need to come up with something else
4. Plus you need to place info on the specific source for the product. Maybe it would be best to put your vendor for the base materials? That sounds like a lot of info and could be considered proprietary so I'm not entirely sure what to do with this-- maybe it's only needed if you license a product through someone else, or if the CPSC would need more info to track down the source if there was an issue with your toy. I don't think anything else is needed but I'll ponder this one.

The label contents, format, and style is completely up to the manufacturer according to the law- so maybe I'll look at a similar toy from a local manufacturer and copy the format of their label. The guidance is that if yours is really terrible they can tell you so by "comparison to a peer". Chew on that!
What law?
You can find the law in section 14(a)(5) of the Consumer Product Safety Act, 15 U.S.C. §2063(a)(5) (CPSA). (The requirement was originally part of section 103 of Product Safety Improvement Act of 2008 (CPSIA) (Public Law 110-314).)
The Commission has also published a statement of policy on this requirement-- this gives you more info and definition beyond what I've provided. Great bedtime reading!

Some Additional Notes:

The label must be permanent- which is OK for me since I can engrave such information- and must be on the packaging and the toy itself. The durability of the label on the packaging only has to be permanent enough to make it to the consumer so a sticker is OK in most cases. On toys that are made to be kept in a box-- like a puzzle or memory/concentration game it is OK that the box is marked and not the individual game pieces (this is good becuase otherwise it would be silly) but I think that type of mark for packaging meant to be reused should be more permanent. OK- so this means an additional engraving run for the game boxes or I can include the info in the label. Let's roll!

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