June 17, 2009 -- SGMA's Legal Task Force - Tracking Labels Section 103 - Statement of Policy (2009)
Under the Consumer Product Safety Improvement Act (CPSIA) children's products manufactured after August 14, 2009 must include tracking labels that help identify the production source. While the new requirement does not force manufacturers to disclose their source of production, they must provide information that helps the government to identify the source.
The CPSC recently provided further clarification on the new requirement:
- The Commission acknowledged there is not a one-size-fits-all solution to compliance and manufacturers must use their best judgment to develop markings that best suit their business and products.
- The CPSC will be lenient on manufacturers for inadvertent violations, provided they made a good faith attempt to comply with the requirements of Section 103.
- The country, city, state, province or administrative region where product was made is sufficient information on the source of production.
- Name of manufacturer or private labeler must be ascertainable on the marking.
- Manufacturers need to consider the totality of information permanently marked on their products and ensure that required information is included.
- Placement of tracking information is not limited to one specific location or label.
- The permanent mark must be placed on a product/packaging so that it is durable enough to reach the consumer.
- Not all products and packaging will be suitable for the required markings. Manufacturers need to provide permanent markings whenever it is practicable or necessary.
As a follow up to the June 17th conference call on 'Tracking Labels', SGMA's Legal Task Force prepared a brief to assist our members' in complying with the new tracking label requirement.
You must be a member and signed in to access the Tracking Label document. If you are a member and do not have your username/password please contact Cameron Jacobs at email@example.com or 202.349.9421. Non-Members who would like to inquire about this CPSC Tracking Label document can contact Jon Michaels at firstname.lastname@example.org or at 202.349.9415.
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