Building a CPSIA tracking label

The manufacturer of a children's product must place permanent, distinguishing marks on the product and its packaging, to the extent practicable (15 U.S.C. 2063(a)(5)(A)). These tracking marks are separate from the Children's Product Certificate: the CPC is a document, and the tracking label is identification on the product itself.

What the marks must let the ultimate purchaser find out (15 U.S.C. 2063(a)(5)(A)(ii)):

1. The manufacturer or private labeler
2. Location of production
3. Date of production
4. Cohort information — the batch, run number, or other identifying characteristic

The marks must also let the manufacturer find out the location and date of production, the cohort information, and any other information the manufacturer decides will help trace the product's specific source (15 U.S.C. 2063(a)(5)(A)(i)).

Placement:

• Permanent — the statute requires permanent marks
• On the product and its packaging — both, to the extent practicable. Where marking one of them isn't practicable, that qualifier is what applies; document why.
• CPSC may exclude a product or class of products for which the marks are not practicable (15 U.S.C. 2063(a)(5)(B))

INFO: A tracking label is identification, not a safety warning. Any warning labels a product needs under other rules are separate requirements, and the tracking label does not replace them.