Tracking labels for kids

[Anne-Marie Fortin]

We are importing boys clothing and I need some clarifications on the tracking labels, actually, on what to appear on these labels, can anyone help?

[Desiree Vittorio]

The CPSC is still taking requests for comments so it is not clear if we need the exact address or just, "Made in China". There are no further clarifications.
Here is the link:
http://www.cpsc.gov/businfo/frnotices/fr09/trackinglabels.html

[S.C.]

Although the CPSA is in a comment period, the Act itself indicates the following regarding tracking labels:

b. Section 103 Tracking labels - (ref. CPSIA Act Section 103 Summary – FAQ’s)
i. Valid for products manufactured on or after 8-14-2009
ii. Requirements
1. Must be a label - no hangtags or stickers
2. Must enable manufacturer to ascertain
a. Location of production
b. Date of production
c. Cohort information
i. Including batch or run #
ii. “Batch or run” is not defined
3. Must enable purchaser to ascertain
a. Manufacturer or private labeler
b. Location of production
c. Date of production
d. Cohort information
i. Including batch or run number
ii. “Batch” or “run” is not defined
e. “Thus, section 103 of the CPSIA does require that the tracking label contain information sufficient for the purchaser to ascertain the manufacturer of the product”

A review and comparison with the requirements (partial-below) for the Conformity Certificate seems to indicate that the original intent was that enough detailed information would be provided to the consumer so that the consumer would be able to track a product all the way back to the factory.

e. Date and place of manufacture
i. Month and year at a minimum
ii. Street address

Whether it will be possible for an importer to indicate the factory/factory location with a code that could be obtained from the importer, rather than the actual factory details, is unknown at this time.