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CPSC Statement of Policy
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CPSC on Tracking Label Requirements
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Children's Product Definition

Tracking Labels

CPSIA §103

 

Provisions on tracking labels require “distinguishing marks” on all children’s products and their packaging. 

The marking labels:

  • Must allow the manufacturer to ascertain the location and date of production, cohort information (including the batch, run number, or other identifying characteristic), and any other information determined by the manufacturer to facilitate ascertaining the specific source of the product; and
  • Must allow the ultimate purchaser to ascertain the manufacturer or private labeler, location and date of production of the product, and cohort information (including the batch, run number, or other identifying characteristic).

The purpose of the marking requirement is to facilitate recalls.  CPSC does not specify any particular system or format of marking. Manufacturers are responsible for making a reasonable judgment about what information can be marked on their product and packaging.

  • Marks must be visible, legible, and reasonably expected to remain on the product for its life.
  • The expectation is that both packaging and product will be marked, unless not practicable.  Circumstances in which it might not be practicable to mark the product itself include very small products, individual pieces in a set, items sold in bulk through vending machines, products that would be damaged by marking, products with surfaces that can’t be marked permanently, and cases in which a mark would ruin the aesthetic of the product.
  • The manufacturer/importer of the children’s product is responsible for compliance.

The materials available and information provided at the Avery Dennison ADvantage: Complete Compliance site are for informational purposes only and not for the purpose of providing legal advice.