Tracking Your Toys

On August 14, 2009, the CPSIA tracking label requirement becomes effective on all children’s products. After several high profile toy recalls The Consumer Products Safety Improvement Act (CPSIA) was enacted in August of 2008 to “establish consumer product safety standards and other safety requirements for children’s products.” Implemented in stages, the next part requires manufacturers to have a tracking label or other distinguishing permanent mark on any consumer product primarily intended for children twelve and younger. Recognizing that it may not be practical for permanent distinguishing marks to be printed on small toys and other small products that are manufactured and shipped without individual packaging, Congress modified the requirement for tracking labels with the phrase “to the extent practicable.” The law requires that markings with the specified information be permanent; therefore, hangtags and adhesive labels are not permanent. Note the term “consumer product” is broad and will require compliance for items such as clothing and shoes, not just toys. All goods in this category, domestic and imported, manufactured after that date must bear the required tracking label.

Although the tracking labels are required effective on Aug. 14, the CPSC has provided very little guidance for implementation.

The tracking label must contain certain basic information, including the
· source of the product,
· date of manufacture and
· detailed information on the manufacturing process, such as a batch or run number.

With less than 6 weeks remaining until the new requirements take effect, let’s hope the CPSC provides some guidance soon!