Building a CPSIA tracking label

Every children's product (intended for children 12 or under) sold in the US must carry a tracking label. The CPSIA tracking label requirement (Section 103) is separate from the Children's Product Certificate — the CPC is a regulatory document, the tracking label is permanent identification on the product itself.

Required information on every tracking label:

1. Manufacturer or private labeler name — full legal name, not a brand-only mark
2. Location of production — city and country where the product was manufactured
3. Date of production — month and year at minimum (some product types require day-level)
4. Cohort information — batch number, run number, or other identifier that ties the unit to a specific production run
5. Any other source-tracing information the manufacturer chooses to include

Formatting requirements:

• Permanent — must survive normal use and washing
• Distinguishing marks must be on the product itself AND its packaging — both, not either
• Visible and legible to a reasonable consumer without special tools
• Encoded formats (QR codes, barcodes) are allowed only if a human-readable equivalent is also present

TIP: For very small products (jewelry, small toys) where a full tracking label won't fit, CPSC accepts an abbreviated label on the product (e.g., a code) plus full information on the packaging. Document the rationale in your CPC file.

WARNING: ASTM F963 toy safety labels (age grading, choking hazard warnings) are separate requirements. A CPSIA tracking label is identification; an ASTM label is safety warning. A children's toy needs both, on the same product, with neither obscuring the other.