June 24, 2009
Required Soon: Tracking Labels on Children's Products
Effective August 14, 2009, section 103(a) of the Consumer Product Safety Improvement Act (CPSIA) will require, to the extent practicable, the placement of permanent, distinguishing marks on children’s products and packaging, according to a statement posted on the Web site of the Office of Textiles and Apparel (OTEXA) and information posted on the U.S. Consumer Product Safety Commission (CPSC) Web site. The URLs for both of these sources are listed at the end of this bulletin as well as the URL for the applicable Federal Register Notice.
The purpose of the label is two-fold:
- It will enable the manufacturer to ascertain the location and date of production of the product, cohort information (including the batch, run number, or other identifying characteristic), and any other information determined by the manufacturer to facilitate ascertaining the specific source of the product by reference to those marks.
- It will enable the ultimate purchaser to ascertain the manufacturer or private labeler, location and date of production of the product, and cohort information (including batch, run number, or other identifying characteristic).
The new law requires manufacturers to have a tracking label or other distinguishing permanent mark on any consumer product designed or primarily intended for children twelve and younger.
The tracking label must contain certain basic information, including the following:
- Source of the product (manufacturer or private labeler)
- Location and date of production of the product
- More detailed information on the manufacturing process, such as a batch, run number, or other identifying characteristic of the product
The scope of this provision is quite broad in that it applies to all children's products, including, but not limited to, clothing, shoes, toys, and other regulated products.
According to a FAQ posted on the CPSC Web site, the tracking label requirement applies to children’s products manufactured on or after August 14, 2009.
Note: U.S. Customs and Border Protection (CBP) marking requirements, inclusive of labeling, require the marking to be permanent enough to reach the end user. The new Track Label requirement is intended to apply to the life of the article.
Additional information on the topic of this bulletin can be obtained at the following Web sites:
Web site of Office of Textiles and Apparel (OTEXA):
http://otexa.ita.doc.gov/.
Web site of the US Consumer Product Safety Commission (CPSC):
The Federal Register notice on the topic of this bulletin (Vol. 74, No. 37 /Thursday, February 26, 2009 / Notices), can be accessed at: http://edocket.access.gpo.gov/2009/pdf/E9-4066.pdf
For more information, please contact your local FedEx Trade Networks Transport & Brokerage office. For a complete list of office locations go to http://www.ftn.fedex.com/locations/index.html.
