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Washington Outlook Archive

CPSC Gives Guidance For New Product Tracking Labels

James A. Morrissey, Washington Correspondent

The Consumer Product Safety Commission (CPSC) has published guidelines for compliance with its new tracking label requirement for products, including textiles and apparel, intended for use by children.

The recently enacted Consumer Product Safety Improvement Act (CPSIA) requires manufacturers of children's products to have permanent distinguishing marks on their products and packaging that will identify the location and date of production and batch number of a product in order to make it easier to track possible safety problems and determine whether the product may be subject to a recall.

The CPSC guidelines say that if a manufacturer can identify the location, date of production and batch number of products or components, it can more easily isolate products that it or others may say presents a safety concern. In enacting the CPSIA regulation, Congress said it was addressing difficulties some manufacturers of children's products and consumers have been experiencing in determining if a product or its components may be subject to recall. CPSC says the labeling requirement is not a "one size fits all" approach, but leaves it up to manufacturers as to what kind of a label is best for their products.

The commission says each manufacturer is ultimately responsible for making a reasonable judgment about what information can be marked on its products and packaging, given the character of each product. It believes the statute requires both packaging and the product to be marked, but it recognizes that there may be some circumstances in which that may not be practical, and adjustments can be made.

The new regulation, which goes into effect August 14, 2009, applies to both imports and domestically manufactured goods, but it does not apply retroactively to products made prior to that date.

July 28, 2009